Legal Opinion
Paul A. Tanner, Sr. and Beverly N. Tanner v. Commissioner
United States Tax Court
Decided December 10, 2001No. 5738-00Unknown
1Opinion of the Court
117 T.C. No. 20
UNITED STATES TAX COURT PAUL A. TANNER, SR. AND BEVERLY N. TANNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5738-00. Filed December 10, 2001. P planned to acquire control of C, a corporation. C required P to sign a lockup agreement, which restricted P’s sale of any C stock. The agreement provided that, if P sold the stock within 2 years of its acquisition, he would be subject to sec. 16(b) of the Securities Exchange Act of 1934. On July 9, 1993, P received a nonstatutory employee stock option from C. On Sept. 7, 1994, P exercised this stock option.…
2Cases cited11 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Ramon Portillo and Dolores Portillo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- Fed. Sec. L. Rep. P 90,216 Magma Power Company v. The Dow Chemical CompanyCourt of Appeals for the Second Circuit · 1998
- Jackie L. And Janet G. McDonald v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1985
- Kolom v. Comm'rUnited States Tax Court · 1978
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