Legal Opinion
Lawrence J. Alves and Myra L. Alves v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided June 5, 1984No. 83-7491PublishedCited by 33 opinions
1Opinion of the Court
SCHROEDER, Circuit Judge.
Lawrence J. Alves appeals a Tax Court decision sustaining the Commissioner’s finding of deficiency for 1974 and 1975. Alves v. Commissioner, 79 T.C. 864 (1982). The appeal -raises an unusual question under section 83 of the Internal Revenue Code, 26 U.S.C. § 83 (1982). Section 83 requires that an employee who has purchased restricted stock in connection with his “performance of services” must include as ordinary income the stock’s appreciation in value between the time of purchase and the time the restrictions lapse, unless at the time he purchased the stock he…
2Cases cited11 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Fulman v. United StatesSupreme Court of the United States · 1978
- Miriam Sakol v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1978
- Alves v. CommissionerUnited States Tax Court · 1982
6 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Venture Funding v. CommissionerUnited States Tax Court · 1998
- Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
- Bagley v. CommissionerUnited States Tax Court · 1985
- Cramer v. CommissionerUnited States Tax Court · 1993
- Anthony Theophilos Patricia A. Theophilos v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1996
28 more not listed; retrieve them via the Exa API.