Legal Opinion

Ellison v. Commissioner

United States Tax Court

Decided October 27, 1970No. Docket No. 1900-68Published

The petitioner exercised a stock option granted to him by the life insurance company for which he was an agent. The agency contract under which he served provided that he was not an employee of the company, but the company retained and exercised the right to control extensively the methods used by the petitioner in performing his work. Held, the petitioner was an employee of the company, and the stock option qualified as a restricted stock option under sec. 424, I.R.C. 1954.

1Opinion of the Court

J. G. Ellison, Petitioner v. Commissioner of Internal Revenue, Respondent

Ellison v. Commissioner

Docket No. 1900-68

United States Tax Court

55 T.C. 142; 1970 U.S. Tax Ct. LEXIS 42;

October 27, 1970, Filed

Decision will be entered for the petitioner.

The petitioner exercised a stock option granted to him by the life insurance company for which he was an agent. The agency contract under which he served provided that he was not an employee of the company, but the company retained and exercised the right to control extensively the methods used by the petitioner in performing his work. Held, the…

2Cases cited15 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. SilkSupreme Court of the United States · 1947
  3. Singer Manufacturing Co. v. RahnSupreme Court of the United States · 1889
  4. Radio City Music Hall Corp. v. United StatesCourt of Appeals for the Second Circuit · 1943
  5. National Labor Relations Board v. Phoenix Mut. L. Ins. Co.Court of Appeals for the Seventh Circuit · 1948

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