Legal Opinion

Kolom v. Comm'r

United States Tax Court

Decided November 21, 1978No. Docket No. 5699-76Published

Held, for purposes of the minimum tax provisions of secs. 56 and 57(a)(6), I.R.C. 1954, the fair market value of relatively small amounts of stock acquired through the exercise of qualified stock options by a taxpayer subject to the insider trading provisions of sec. 16(b), Securities Exchange Act of 1934, is the mean price at which the stock was sold on the New York Stock Exchange on the date of exercise of the stock options.

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Held, for purposes of the minimum tax provisions of secs. 56 and 57(a)(6), I.R.C. 1954, the fair market value of relatively small amounts of stock acquired through the exercise of qualified stock options by a taxpayer subject to the insider trading provisions of sec. 16(b), Securities Exchange Act of 1934, is the mean price at which the stock was sold on the New York Stock Exchange on the date of exercise of the stock options. Held, further, the minimum tax provisions of secs. 56 and 57(a)(6) as applied to the facts of this case are not unconstitutional. Held, further, the determination of…

1Opinion of the Court

Aaron L. Kolom and Serita Kolom, Petitioners v. Commissioner of Internal Revenue, Respondent

Kolom v. Comm'r

Docket No. 5699-76

United States Tax Court

71 T.C. 235; 1978 U.S. Tax Ct. LEXIS 26;

November 21, 1978

Decision will be entered for the respondent.

Held, for purposes of the minimum tax provisions of secs. 56 and 57(a)(6), I.R.C. 1954, the fair market value of relatively small amounts of stock acquired through the exercise of qualified stock options by a taxpayer subject to the insider trading provisions of sec. 16(b), Securities Exchange Act of 1934, is the mean price at which the stock was…

2Cases cited23 opinions

  1. United States v. CartwrightSupreme Court of the United States · 1973
  2. Commissioner v. LoBueSupreme Court of the United States · 1956
  3. Commissioner v. SmithSupreme Court of the United States · 1945
  4. Arrowsmith v. CommissionerSupreme Court of the United States · 1952
  5. Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963

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