Legal Opinion

Alves v. Commissioner

United States Tax Court

Decided November 18, 1982No. Docket No. 4879-80Published

In 1970, Lawrence J. Alves purchased 40,000 shares of stock of a new corporation by which he became employed for the fair market value of the stock at the date of purchase. His employment agreement stated that one of the reasons for issuance of the stock was to provide the employee with additional interest in the company.

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In 1970, Lawrence J. Alves purchased 40,000 shares of stock of a new corporation by which he became employed for the fair market value of the stock at the date of purchase. His employment agreement stated that one of the reasons for issuance of the stock was to provide the employee with additional interest in the company. Two-thirds of the stock was restricted from being sold prior to the expiration of a stated period and, if the employee left the employ of the corporation prior to the expiration of that period, the company could repurchase the stock at the amount the employee paid for it.…

1Opinion of the Court

Lawrence J. Alves and Myra L. Alves, Petitioners v. Commissioner of Internal Revenue, Respondent

Alves v. Commissioner

Docket No. 4879-80

United States Tax Court

79 T.C. 864; 1982 U.S. Tax Ct. LEXIS 17; 79 T.C. No. 55;

November 18, 1982, Filed

Decision will be entered under Rule 155.

In 1970, Lawrence J. Alves purchased 40,000 shares of stock of a new corporation by which he became employed for the fair market value of the stock at the date of purchase. His employment agreement stated that one of the reasons for issuance of the stock was to provide the employee with additional interest in the…

Also in this document: Dissent · Fay; Dissent · Whitaker.

2Cases cited12 opinions

  1. Lemmen v. CommissionerUnited States Tax Court · 1981
  2. Miriam Sakol v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1978
  3. Sakol v. CommissionerUnited States Tax Court · 1977
  4. Tufts v. CommissionerUnited States Tax Court · 1978
  5. Gresham v. CommissionerUnited States Tax Court · 1982

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