Morris v. Commissioner
United States Tax Court
Petitioners were granted options to purchase corporate stock of their employer pursuant to a written plan. Held, on the dates the options were granted, the fair market value of the stock was not in excess of the option price. Held, further, the options were granted on the date that the corporation received from the State of California Corporation Commission approval to issue shares pursuant to the plan.
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Petitioners were granted options to purchase corporate stock of their employer pursuant to a written plan. Held, on the dates the options were granted, the fair market value of the stock was not in excess of the option price. Held, further, the options were granted on the date that the corporation received from the State of California Corporation Commission approval to issue shares pursuant to the plan. Held, further, fair market value of stock determined for the dates that petitioners exercised options. Held, further: Determination made as to the extent that five petitioners each owned more…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in Federal income taxes of petitioners as follows:
Docket Taxable
Petitioner No. year Deficiency
Jerald D. and Joan C. Morris . 5589-74 1970 $9,987.37
Harlod S. and Ruth S. T. Yang . 5619-74 1970 69,573.65
Jack Roy and Bettylou Allgaier .10237-75 1970 6,051.89
Russell K. and Elizabeth S. Brunner .10238-75 1969 10238-75 1970 10238-75 1971 251,324.00 476,624.00 5,407.00
Stanley F. and Judith G. Brown .10239-75 1970 104,213.00
Thurman P. and Marquerite C. Chappell .10240-75 1970 10240-75 1972 8,662.35 2,541.04
Robert B. and Earlene D. Crouch .10241-75…
2Cases cited15 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Interstate Circuit, Inc. v. United StatesSupreme Court of the United States · 1939
- United States v. CartwrightSupreme Court of the United States · 1973
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
10 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Dellacroce v. CommissionerUnited States Tax Court · 1984
- BBS Associates, Inc. v. CommissionerUnited States Tax Court · 1980
- Berry Petroleum Co. v. CommissionerUnited States Tax Court · 1995
- Estate of Pullin v. CommissionerUnited States Tax Court · 1985
- Robinson v. CommissionerUnited States Tax Court · 1984
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