Legal Opinion

Commissioner of Internal Revenue v. Philip J. Lo Bue

Court of Appeals for the Third Circuit

Decided June 9, 1955No. 11524_1PublishedCited by 9 opinions

1Opinion of the Court

MARIS, Circuit Judge.

This ease involves the taxability as compensation to the taxpayer of the difference between the purchase price and market value of stock in his employer, Michigan Chemical Corporation, which was acquired by him pursuant to stock options granted to him as an employee by that corporation. The facts are set out at length in the opinion of the Tax Court in this case, 22 T.C. 440, and need not be repeated here. Suffice it to say that the Commissioner of Internal Revenue determined a deficiency in income tax against the taxpayer for the years 1946 and 1947 with respect to stock…

2Cases cited21 opinions

  1. Commissioner v. SmithSupreme Court of the United States · 1945
  2. Commissioner of Internal Revenue v. Van VorstCourt of Appeals for the Ninth Circuit · 1932
  3. Taplin v. CommissionerCourt of Appeals for the Sixth Circuit · 1930
  4. Erskine v. CommissionerUnited States Board of Tax Appeals · 1932
  5. McNamara v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1954

16 more not listed; retrieve them via the Exa API.

3Cited by9 opinions

  1. Commissioner v. LoBueSupreme Court of the United States · 1956
  2. Spirt v. BechtelCourt of Appeals for the Second Circuit · 1956
  3. Union Chemical & Materials Corp. v. United StatesUnited States Court of Claims · 1961
  4. LoBue v. CommissionerUnited States Tax Court · 1957
  5. Commissioner v. LoBueSupreme Court of the United States · 1956

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