Kast v. Commissioner
United States Tax Court
Each petitioner in 1976 exercised his option to purchase stock of his employer, K Corp., such option having been granted to him pursuant to a qualified stock option plan adopted by the employer. The option price was $ 7 per share; in 1976, at the time the options were exercised, the stock had a fair market value of $ 13.25 per share.
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Each petitioner in 1976 exercised his option to purchase stock of his employer, K Corp., such option having been granted to him pursuant to a qualified stock option plan adopted by the employer. The option price was $ 7 per share; in 1976, at the time the options were exercised, the stock had a fair market value of $ 13.25 per share. In 1977, K Corp. adopted a plan of liquidation and, pursuant to such liquidation, each petitioner as a shareholder in 1977 received a distribution of $ 15.30 per share and further distributions in 1978 and 1979. Each petitioner had voted against the adoption of…
1Opinion of the Court
Francis X. Kast and Anne E. Kast, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Kast v. Commissioner
Docket Nos. 13643-81, 14902-81, 14903-81, 22428-81, 26661-81, 29082-81, 29083-81, 1035-82
United States Tax Court
78 T.C. 1154; 1982 U.S. Tax Ct. LEXIS 72; 78 T.C. No. 81;
June 29, 1982, Filed
Appropriate orders and decisions will be entered in all cases except Warren H. Schumann and Maria T. Schumann, docket No. 26661-81, and an appropriate order will be entered in that case.
Each petitioner in 1976 exercised his option to purchase stock of his employer, K Corp., such option…
Also in this document: Dissent.
2Cases cited14 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- United States v. DavisSupreme Court of the United States · 1970
- Hotel Equities Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1976
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