Legal Opinion

Mason v. Commissioner

United States Board of Tax Appeals

Decided May 29, 1940No. Docket No. 97350Published

Where a taxpayer enters into a contract of employment providing, together with other compensation, a bonus, measured in money, computed upon net earnings of the employer, and an inseparable provision of that same contract obligates the taxpayer to exchange such money, concurrently with its receipt, for stock of the employing company at a fixed value, held, the taxpayer realizes taxable income in the amount of the fair market value of such stock when he receives it.

1Opinion of the Court

GEORGE W. MASON AND HAZEL B. MASON, HIS WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Mason v. Commissioner

Docket No. 97350.

United States Board of Tax Appeals

41 B.T.A. 1287; 1940 BTA LEXIS 1072;

May 29, 1940, Promulgated

Where a taxpayer enters into a contract of employment providing, together with other compensation, a bonus, measured in money, computed upon net earnings of the employer, and an inseparable provision of that same contract obligates the taxpayer to exchange such money, concurrently with its receipt, for stock of the employing company at a fixed value, held,…

2Cases cited1 opinion

  1. Mason v. CommissionerUnited States Board of Tax Appeals · 1940

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