M. P. Frank and Beatrice Frank v. Commissioner of Internal Revenue

SWYGERT, Chief Judge.

This is a petition to review a decision of the United States Tax Court1 which determined deficiencies in the federal income taxes for calendar year 1960 paid by petitioners-appellants.2 The Tax Court determined that taxpayer realized ordinary income in the amount of $530,328.66 during that year due to the exercise on September 28, 1960 of stock options granted in 1958 to M. P. Frank by Mortgage Guaranty Insurance Company (“MGIC”) and Guaranty Insurance Agency, Inc. (“GIAI”), both Wisconsin corporations. Taxpayer appeals the de*554terminations of the Tax Court that: (1) M. P.…