Legal Opinion
Commissioner v. Smith
Supreme Court of the United States
Decided March 26, 1945No. 371PublishedCited by 253 opinions
1Opinion of the CourtChief Justice Stone
Respondent’s employer gave to him, as compensation for his services, an option to purchase from the employer certain shares of stock of another corporation at a price not less than the then value of the stock. In two later tax years, when the market value of the stock was greater than the option price, respondent exercised the option, purchasing large amounts of the stock in each year. The question for decision is whether the difference between the market value and the option price of the stock was compensation for personal services of the employee, taxable as income in the years when he…
2Cases cited6 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Helvering v. San Joaquin Fruit & Investment Co.Supreme Court of the United States · 1936
- Shuster v. HelveringCourt of Appeals for the Second Circuit · 1941
- Connolly's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
1 more not listed; retrieve them via the Exa API.
3Cited by253 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Sachs v. CommissionerUnited States Tax Court · 1959
- Musmeci v. Schwegmann Giant Super Markets, Inc.Court of Appeals for the Fifth Circuit · 2003
- United States v. Sherrill O. And Doris M. Woodall, Husband and Wife, United States of America v. Glenn S. And Margaret H. Mills, Husband and WifeCourt of Appeals for the Tenth Circuit · 1958
248 more not listed; retrieve them via the Exa API.