Le Vant v. Commissioner
United States Tax Court
In an employment agreement dated April 22, 1957, between petitioner and his employer, Edison Co., petitioner was granted an option to purchase a 20-percent interest in the business of Edison Co., or its successor, for $ 50,000, exercisable for a period of 2 years beginning on January 1, 1958. In a transaction whereby Colgate-Palmolive Co. acquired all the stock of Edison, Inc., successor to Edison Co., in exchange for stock of Colgate, petitioner transferred all of his…
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In an employment agreement dated April 22, 1957, between petitioner and his employer, Edison Co., petitioner was granted an option to purchase a 20-percent interest in the business of Edison Co., or its successor, for $ 50,000, exercisable for a period of 2 years beginning on January 1, 1958. In a transaction whereby Colgate-Palmolive Co. acquired all the stock of Edison, Inc., successor to Edison Co., in exchange for stock of Colgate, petitioner transferred all of his rights under the April 22, 1957, employment agreement, including the option, to Colgate in exchange for 6,494 shares of…
1Opinion of the Court
DkbNNEN, Judge :
Respondent determined a deficiency in petitioner’s income tax for the taxable year 1960 in the amount of $124,021.02.
The issues for decision arise from a transaction in 1960 by which petitioner, Jack I. LeVant (hereafter referred to as petitioner or LeVant), exchanged an option to purchase a 20-percent interest in the business of S. M. Edison Chemical Co., Inc. (hereafter referred to as Edison, Inc.), for 6,494 shares of stock of Colgate-Palmolive Co. (hereafter referred to as Colgate).
The first issue is whether gain which petitioner realized upon the exchange is to be…
2Cases cited14 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- June M. Carlberg, by Vida M. Frick, Guardian v. United StatesCourt of Appeals for the Eighth Circuit · 1960
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3Cited by27 opinions
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- Frank v. CommissionerUnited States Tax Court · 1970
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