Joseph Frank v. Commissioner of Internal Revenue

Petitioner, who was an employee of The Interstate Folding Box Company, and for many years its secretary and principal accountant, resigned in 1946 after a sharp disagreement with Interstate’s president. He owned 100 shares of stock in the company, which he was required on resignation to sell back to Interstate. In settlement of all claims against Interstate, including the amount paid for his stock and all bonuses and salary due him, he received the sum of $50,641.30 in three payments, one a check dated December 28, 1946, in the amount of $18,701.02 which bore the words ■“Stock Purchase”;…