Haberman v. Commissioner
United States Board of Tax Appeals
1. The taxpayer agreed with a corporation to remain in the employ of one of its subsidiaries for three years, beginning January 1, for a compensation consisting of a stated cash salary and the right to purchase a stated number of shares of the stock of the parent. Stock certificates for fully issued and paid-up shares were issued to the taxpayer and were immediately endorsed by him and deposited with the parent to secure a loan for the full purchase price of all the shares.
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1. The taxpayer agreed with a corporation to remain in the employ of one of its subsidiaries for three years, beginning January 1, for a compensation consisting of a stated cash salary and the right to purchase a stated number of shares of the stock of the parent. Stock certificates for fully issued and paid-up shares were issued to the taxpayer and were immediately endorsed by him and deposited with the parent to secure a loan for the full purchase price of all the shares. Upon payment of one third of the loan, with interest, on or before January 2 following each calendar year, the taxpayer…
1Opinion of the Court
PHILLIP W. HABERMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
FRANK W. COLLINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Haberman v. Commissioner
Docket Nos. 54426, 59149, 62542.
United States Board of Tax Appeals
31 B.T.A. 75; 1934 BTA LEXIS 1168;
August 10, 1934, Promulgated
1. The taxpayer agreed with a corporation to remain in the employ of one of its subsidiaries for three years, beginning January 1, for a compensation consisting of a stated cash salary and the right to purchase a stated number of shares of the stock of the parent. Stock certificates for…
2Cases cited2 opinions
- Erskine v. CommissionerUnited States Board of Tax Appeals · 1932
- Haberman v. CommissionerUnited States Board of Tax Appeals · 1934