Jordan v. Commissioner
United States Tax Court
1. Petitioners, and others, organized and incorporated R corporation and received options to purchase stock. They sold their stock option rights to Q corporation, which in turn exercised the options and sold the stock to the public. The stock purchased pursuant to the options was unrestricted as to future sale by the shareholders whereas the original issue of R corporation stock was subject to certain restrictions.
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1. Petitioners, and others, organized and incorporated R corporation and received options to purchase stock. They sold their stock option rights to Q corporation, which in turn exercised the options and sold the stock to the public. The stock purchased pursuant to the options was unrestricted as to future sale by the shareholders whereas the original issue of R corporation stock was subject to certain restrictions. After being informed by legal counsel that there were possible violations of SEC rules, petitioner entered into an offer of rescission transaction whereby he (and the other…
1Opinion of the Court
Wiles, Judge:*
Respondent determined deficiencies in petitioners’ income taxes for the years 1962 through 1966 in the amounts as follows:
Glen A. and Virginia D. Jordan
Year Amount of deficiency
1962 _$103,591.00
1963 _ 24, 731.00
1964 _ 13,267.00
1965 _ 62,005.99
1966 _ 1,946.67
Insurance Sales & Management Co.
Addition to tax
Year Amount of deficiency sec. 6651 (a)
Oct. 31, 1963_ $1, 675. 57 _
Oct. 31, 1964_ 648. 08 $97. 21
Several issues have been settled by the parties prior to this trial. The remaining issues are:(1) Whether expenditures by petitioner which resulted in the acquisition of stock are…
2Cases cited26 opinions
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Ach v. CommissionerUnited States Tax Court · 1964
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Rubin v. CommissionerUnited States Tax Court · 1971
21 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Lemmen v. CommissionerUnited States Tax Court · 1981
- Nestle Holdings v. CommissionerUnited States Tax Court · 1995
- Entwicklungs und Finanzierungs A.G. v. CommissionerUnited States Tax Court · 1977
- Stokely-Van Camp, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1992
- Lorch v. CommissionerUnited States Tax Court · 1978
22 more not listed; retrieve them via the Exa API.