Legal Opinion

Brown Shoe Co. v. Commissioner

United States Board of Tax Appeals

Decided September 26, 1941No. Docket No. 102047Published

Because of a desire to assure itself of the services of its president, petitioner optioned 8,000 shares of its capital stock to him at a price slightly over its then market value, in consideration for which its president agreed to serve as such officer, at his then prevailing compensation, for five years more.

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Because of a desire to assure itself of the services of its president, petitioner optioned 8,000 shares of its capital stock to him at a price slightly over its then market value, in consideration for which its president agreed to serve as such officer, at his then prevailing compensation, for five years more. During the fiscal year ending October 31, 1937, petitioner sold 1,500 shares of its previously purchased stock to its president under this option and, in the same year, sold 1,000 of the purchased shares released by its president and an additional 1,000 shares to key employees at a…

1Opinion of the Court

BROWN SHOE COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Brown Shoe Co. v. Commissioner

Docket No. 102047.

United States Board of Tax Appeals

45 B.T.A. 212; 1941 BTA LEXIS 1157;

September 26, 1941, Promulgated

Because of a desire to assure itself of the services of its president, petitioner optioned 8,000 shares of its capital stock to him at a price slightly over its then market value, in consideration for which its president agreed to serve as such officer, at his then prevailing compensation, for five years more. During the fiscal year ending October 31, 1937,…

2Cases cited17 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Eisner v. MacOmberSupreme Court of the United States · 1920
  3. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  4. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  5. Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939

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