Apple Computer, Inc. v. Commissioner
United States Tax Court
P granted to certain employees nonstatutory stock options which did not have readily ascertainable fair market values at grant.
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P granted to certain employees nonstatutory stock options which did not have readily ascertainable fair market values at grant. P treated the income generated upon the exercise of the stock options as wages for purposes of the credit for increasing research activities under sec. 44F (now sec. 41), I.R.C. 1. Held, income generated upon the exercise of the nonstatutory stock options in question (spreads) constitutes "wages paid or incurred to an employee for qualified services performed by such employee" under sec. 44F(b)(2)(A)(i), I.R.C. 2. Held, further, the spreads qualify for the sec. 44F…
1Opinion of the Court
Apple Computer, Inc. and Consolidated Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Apple Computer, Inc. v. Commissioner
Docket No. 34127-87
United States Tax Court
98 T.C. 232; 1992 U.S. Tax Ct. LEXIS 20; 98 T.C. No. 18;
March 3, 1992, Filed
An appropriate order will be issued.
P granted to certain employees nonstatutory stock options which did not have readily ascertainable fair market values at grant. P treated the income generated upon the exercise of the stock options as wages for purposes of the credit for increasing research activities under sec. 44F (now sec. 41),…
2Cases cited13 opinions
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- Commissioner v. LoBueSupreme Court of the United States · 1956
- Demarest v. ManspeakerSupreme Court of the United States · 1991
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- United States v. Hughes Properties, Inc.Supreme Court of the United States · 1986
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