Aaron L. Kolom and Serita Kolom v. Commissioner of Internal Revenue

WALLACE, Circuit Judge:

Aaron L. Kolom and Serita Kolom 1 appeal from a decision of the United States Tax Court determining a deficiency in their federal income tax for the taxable year 1972 in the amount of $43,792. The issue before us is whether restrictions placed upon the sale of stock by section 16(b) of the Securities Exchange Act of 1934 (the Act) affect the valuation of stock for purposes of asserting a minimum tax when stock options are exercised. We affirm.

I

During the taxable year 1972, Kolom was an officer and director of Tool Research and Engineering Corporation (Tool Research).…