Legal Opinion

Lighthill v. Commissioner

United States Tax Court

Decided August 31, 1976No. Docket No. 713-75Published

One of petitioners in 1967 acquired through his employment a nonstatutory stock option which he exercised on June 10, 1968, acquiring stock restricted as to sale. The restrictions were removed on Mar. 14, 1969, and on Mar. 19, 1969, petitioner sold one-third of the stock.

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One of petitioners in 1967 acquired through his employment a nonstatutory stock option which he exercised on June 10, 1968, acquiring stock restricted as to sale. The restrictions were removed on Mar. 14, 1969, and on Mar. 19, 1969, petitioner sold one-third of the stock. Held: Petitioners realized ordinary income from services on Mar. 14, 1969, when the restriction on sale of the stock ended in the amount of the difference between the fair market value of the stock without restrictions as to sale as of June 10, 1968, and the cost of the stock. In computing capital gain on sale of the stock…

1Opinion of the Court

Olaf B. Lighthill and Nadine Lighthill, Petitioners v. Commissioner of Internal Revenue, Respondent

Lighthill v. Commissioner

Docket No. 713-75

United States Tax Court

66 T.C. 940; 1976 U.S. Tax Ct. LEXIS 51;

August 31, 1976, Filed

Decision will be entered under Rule 155.

One of petitioners in 1967 acquired through his employment a nonstatutory stock option which he exercised on June 10, 1968, acquiring stock restricted as to sale. The restrictions were removed on Mar. 14, 1969, and on Mar. 19, 1969, petitioner sold one-third of the stock. Held: Petitioners realized ordinary income from services on…

2Cases cited12 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Commissioner v. LoBueSupreme Court of the United States · 1956
  3. Edgar v. CommissionerUnited States Tax Court · 1971
  4. Lehman v. CommissionerUnited States Tax Court · 1951
  5. United States v. William D. Frazell and Martha T. FrazellCourt of Appeals for the Fifth Circuit · 1964

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