Bavis v. Commissioner
United States Tax Court
Petitioners, key employees of the Chichester Chemical Company owned by D. D. Chidester, agreed after Chidester's death in 1927 to remain with the Company in consideration of the salaries which they were then receiving plus a ratable share of 6 per cent of gross sales of the Company.
Read the full summary
Petitioners, key employees of the Chichester Chemical Company owned by D. D. Chidester, agreed after Chidester's death in 1927 to remain with the Company in consideration of the salaries which they were then receiving plus a ratable share of 6 per cent of gross sales of the Company. Chidester owed large amounts of debts at the time of his death and his wife, who was executrix of his estate, agreed with the creditors that the Company should be operated under an agreement with the creditors providing for their eventual payment. The key employees of the Company, including petitioners, agreed to…
1Opinion of the Court
OPINION.
Black, Judge:
Issue 1.
This issue raises the following question: Are the petitioners entitled to apply the provisions of section 107(d) of the Code to the fair market value of certain shares of stock received from their employer in 1946 pursuant to the terms of a previous contract with said employer, or is such amount all taxable as income in the year when received? The applicable section of the statute and Treasury regulations are printed in the margin.1
There can be no doubt from the facts which have been stipulated that the shares of stock in the newly organized corporation which were…
2Cases cited3 opinions
- Langer v. CommissionerUnited States Tax Court · 1951
- Langer's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950
- C. Abbott Lindsey and Pauline Lindsey v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eleanore Langer, Commissioner of Internal Revenue v. Estate of R. L. Langer, DeceasedCourt of Appeals for the Ninth Circuit · 1952
3Cited by11 opinions
- Donahoe v. CommissionerUnited States Tax Court · 1954
- Mt. Vernon Gardens, Inc. v. CommissionerUnited States Tax Court · 1960
- Roy R. Brooks and Betty B. Brooks v. United StatesCourt of Appeals for the Fifth Circuit · 1960
- Estate of Thoreson v. CommissionerUnited States Tax Court · 1954
- Thoreson v. CommissionerUnited States Tax Court · 1954
6 more not listed; retrieve them via the Exa API.