Legal Opinion

Harold E. MacDonald and Marian B. MacDonald v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided February 13, 1956No. 18-3670PublishedCited by 17 opinions

1Opinion of the Court

MAJOR, Circuit Judge.

This case is here on a petition to review a decision of the Tax Court, entered January 11, 1955, sustaining an asserted deficiency in the income tax of Harold E. MacDonald and Marian B. MacDonald for the taxable year 1949, in the amount of $102,732.30. The Tax Court in sustaining the deficiency as asserted by the Commissioner held that a stock option granted in 1948 by Household Finance Corporation (referred to as Household) to petitioner, Harold E. MacDonald, was compensatory in character and hence taxable when exercised in 1949. The deficiency is predicated upon the…

2Cases cited11 opinions

  1. Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
  2. Commissioner v. SmithSupreme Court of the United States · 1945
  3. Smolowe v. Delendo CorporationCourt of Appeals for the Second Circuit · 1943
  4. Park & Tilford, Inc. v. SchulteCourt of Appeals for the Second Circuit · 1947
  5. O'malley, Collector of Internal Revenue v. AmesCourt of Appeals for the Eighth Circuit · 1952

6 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Kolom v. Comm'rUnited States Tax Court · 1978
  2. Aaron L. Kolom and Serita Kolom v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
  3. Hirsch v. CommissionerUnited States Tax Court · 1968
  4. Arc Realty Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1961
  5. Arc Realty Co. v. CommissionerUnited States Tax Court · 1960

12 more not listed; retrieve them via the Exa API.

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