Husted v. Commissioner
United States Tax Court
The petitioner rendered substantial services in arranging for the Dorsey Corp. to acquire a trailer-manufacturing business. As a part of the plan for the acquisition of such business, the petitioner was permitted to acquire Dorsey stock at a price less than its fair market value.
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The petitioner rendered substantial services in arranging for the Dorsey Corp. to acquire a trailer-manufacturing business. As a part of the plan for the acquisition of such business, the petitioner was permitted to acquire Dorsey stock at a price less than its fair market value. Held, allowing the petitioner to acquire the Dorsey stock for less than its fair market value was the payment of compensation for his services in arranging the acquisition of the trailer business; the fair market value of the stock acquired by the petitioner is determined by taking into consideration the restrictions…
1Opinion of the Court
Simpson, Judge:
The respondent determined a deficiency of $291,-662.85 in the petitioner’s income tax for 1959. However, at the trial the respondent increased the deficiency by alleging that the petitioner earned an additional $42,600 in 1959. The issues remaining for decision are: (1) Whether the petitioner, who arranged for the Dorsey Corp. to acquire a trailer-manufacturing business, received compensation when he was allowed to acquire Dorsey stock for less than its fair market value as part of the plan for the acquisition of such business; (2) whether the petitioner actually paid $42,600…
2Cases cited13 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- Palmer v. CommissionerSupreme Court of the United States · 1937
8 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Estate of Gilford v. CommissionerUnited States Tax Court · 1987
- Jackie L. And Janet G. McDonald v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1985
- Estate of Piper v. CommissionerUnited States Tax Court · 1979
- Kolom v. Comm'rUnited States Tax Court · 1978
- Greenspun v. CommissionerUnited States Tax Court · 1979
33 more not listed; retrieve them via the Exa API.