Cramer v. Commissioner
United States Tax Court
Ps controlled corporation I. In 1978, 1979, and 1981, I issued options, containing restrictions on vesting and transfer, to Ps, in connection with their performance of services for I. The 1981 options were contributed to a trust. For certain of the options, Ps filed " I.R.C. sec. 83(b) elections", in which elections Ps reported the fair market value of the options as zero.
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Ps controlled corporation I. In 1978, 1979, and 1981, I issued options, containing restrictions on vesting and transfer, to Ps, in connection with their performance of services for I. The 1981 options were contributed to a trust. For certain of the options, Ps filed " I.R.C. sec. 83(b) elections", in which elections Ps reported the fair market value of the options as zero. Upon the sale of the options to an unrelated company in 1982, Ps reported the sales proceeds as gains from the sale of capital assets, misdescribing the transactions on their returns. R determined that the sale of the…
1Opinion of the Court
Cohen, Judge:
In these consolidated cases, respondent determined deficiencies in and additions to petitioners’ Federal income taxes as follows:
Richard A. and Alice D. Cramer
Docket No. 27682-90
Additions to tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1982 $7,802,334 $390,117 1 $1,950,584
Warren K. and Susi M. Boynton
Docket No. 27684-90
Additions to tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1982 $2,314,440 $115,722 1a $578,610
Kevin P. and Dina E. Monaghan
Docket No. 29100-90
Additions to tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
$4,147 h-CD -3 CD
619,…
2Cases cited40 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
35 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Richard A. Cramer Alice D. Cramer Warren K. Boynton Susi M. Boynton Kevin P. Monaghan Dina A. Monaghan v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Joseph P. Caulfield v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994
- McCoy Enterprises, Inc., & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1995
- CORCORAN v. COMMISSIONERUnited States Tax Court · 2002
21 more not listed; retrieve them via the Exa API.