Kane v. Commissioner
United States Tax Court
An option to purchase stock during periods of the husband's employment was given to the wife by the chief stockholder and chairman of the board of directors of the corporation which employed her husband. When the option was exercised in three instances, the market prices of the stock exceeded the option price. Upon the entire evidence, held, that the option to purchase the stock was intended as additional compensation for the husband's services to the corporation.
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An option to purchase stock during periods of the husband's employment was given to the wife by the chief stockholder and chairman of the board of directors of the corporation which employed her husband. When the option was exercised in three instances, the market prices of the stock exceeded the option price. Upon the entire evidence, held, that the option to purchase the stock was intended as additional compensation for the husband's services to the corporation. Held, further, that the excess of the market value of the stock over the option price in each year in which stock was purchased…
1Opinion of the Court
Joseph Kane, Petitioner, v. Commissioner of Internal Revenue, Respondent. Rose Kane, Petitioner, v. Commissioner of Internal Revenue, Respondent
Kane v. Commissioner
Docket Nos. 50587, 52755, 52756
United States Tax Court
25 T.C. 1112; 1956 U.S. Tax Ct. LEXIS 258;
February 29, 1956, Filed
In Docket Nos. 50587 and 52755 decisions will be entered for the respondent.
In Docket No. 52756 decision will be entered for the petitioner.
An option to purchase stock during periods of the husband's employment was given to the wife by the chief stockholder and chairman of the board of directors of the corporation…
2Cases cited11 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Corliss v. BowersSupreme Court of the United States · 1930
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Commissioner v. SmithSupreme Court of the United States · 1945
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