Legal Opinion
Nield and Linda Montgomery v. Commissioner
United States Tax Court
Decided August 28, 2006No. 633-05Unknown
1Opinion of the Court
127 T.C. No. 3
UNITED STATES TAX COURT NIELD AND LINDA MONTGOMERY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 633-05. Filed August 28, 2006. P-H, president and CEO of MGC Communications, Inc. (MGC), received incentive stock options (ISOs) from MGC between April 1996 and March 1999. In November 1999, P-H resigned as president and CEO of MGC and entered into an employment contract with MGC which included provisions accelerating the vesting dates of his ISOs. In early 2000, P-H exercised many of his ISOs. P-H subsequently sold shares of MGC stock in 2000 and 2001 at…
2Cases cited14 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Fed. Sec. L. Rep. P 90,216 Magma Power Company v. The Dow Chemical CompanyCourt of Appeals for the Second Circuit · 1998
- Allen v. Comm'rUnited States Tax Court · 2002
- Fed. Sec. L. Rep. P 90,280 Margaret Gwozdzinsky, Derivatively on Behalf of Revco D.S., Inc. v. Zell/chilmark Fund, L.P. And Revco D.S., Inc.Court of Appeals for the Second Circuit · 1998
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