Robinson v. Commissioner
United States Tax Court
Held, date of grant of nonqualified employee stock option determined to be subsequent to Apr. 22, 1969, the effective date of sec. 83, I.R.C. 1954. Held, further, the compensation element in the option was taxable in year of exercise.
1Opinion of the Court
Whitaker, Judge:
Respondent determined a deficiency of $1,446,365.51 in the income tax of the petitioners Prentice I. and Rosalie Robinson (the Robinsons) in docket No. 18038-80 for the taxable year 1974, based upon their failure to report income in that year from the exercise of a stock option (the Option) granted Prentice I. Robinson (Robinson) by Centronics Data Computer Corp. and Subsidiaries (Centronics), the petitioner in docket No. 2951-82. Among other items, respondent determined a deficiency in Centronics’ income tax in its 1975 taxable year caused by the disallowance of a $2,958,000…
2Cases cited28 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Rogers v. Guaranty Trust Co.Supreme Court of the United States · 1933
- Kerbs v. California Eastern Airways, Inc.Supreme Court of Delaware · 1952
- Gottlieb v. Heyden Chemical Corp.Supreme Court of Delaware · 1952
- Kolom v. Comm'rUnited States Tax Court · 1978
23 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Pagel, Inc. v. CommissionerUnited States Tax Court · 1988
- Venture Funding v. CommissionerUnited States Tax Court · 1998
- Bagley v. CommissionerUnited States Tax Court · 1985
- Hilen v. Comm'rUnited States Tax Court · 2005
- Koss v. CommissionerUnited States Tax Court · 1989
10 more not listed; retrieve them via the Exa API.