Morris v. Commissioner
United States Tax Court
Petitioners were granted options to purchase corporate stock of their employer pursuant to a written plan. Held, on the dates the options were granted, the fair market value of the stock was not in excess of the option price. Held, further, the options were granted on the date that the corporation received from the State of California Corporation Commission approval to issue shares pursuant to the plan.
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Petitioners were granted options to purchase corporate stock of their employer pursuant to a written plan. Held, on the dates the options were granted, the fair market value of the stock was not in excess of the option price. Held, further, the options were granted on the date that the corporation received from the State of California Corporation Commission approval to issue shares pursuant to the plan. Held, further, fair market value of stock determined for the dates that petitioners exercised options. Held, further: Determination made as to the extent that five petitioners each owned more…
1Opinion of the Court
Jerald D. and Joan C. Morris, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Morris v. Commissioner
Docket Nos. 5589-74, 5619-74, 10237-75 -- 10263-75
United States Tax Court
70 T.C. 959; 1978 U.S. Tax Ct. LEXIS 56;
September 18, 1978, Filed
Decisions will be entered under Rule 155.
Petitioners were granted options to purchase corporate stock of their employer pursuant to a written plan. Held, on the dates the options were granted, the fair market value of the stock was not in excess of the option price. Held, further, the options were granted on the date that the corporation…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Interstate Circuit, Inc. v. United StatesSupreme Court of the United States · 1939
- United States v. CartwrightSupreme Court of the United States · 1973
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
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