Becker v. Commissioner
United States Tax Court
Petitioner had an option to purchase shares of stock of his employer under a restricted stock option plan which required written notice to the company's treasurer at St. Paul, Minn., of his intention to exercise his option, together with full payment. On June 14, 1960, he placed his signed notice and check in the company mail at its Ridgefield, N.J., office, where he was employed.
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Petitioner had an option to purchase shares of stock of his employer under a restricted stock option plan which required written notice to the company's treasurer at St. Paul, Minn., of his intention to exercise his option, together with full payment. On June 14, 1960, he placed his signed notice and check in the company mail at its Ridgefield, N.J., office, where he was employed. This mail, in normal course by air mail, would reach the St. Paul office on June 15. The stock certificate was issued June 20. Petitioner sold the stock on the New York Stock Exchange on December 15, 1960. Held,…
1Opinion of the Court
Bkuge, Judge:
Respondent determined a deficiency in income fax in the amount of $1,141 for the calendar year 1960. The sole issue for decision is whether shares of stock sold by George J. Becker were held by him for more than 6 months.
FINDINGS OF FACT
The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference.
The petitioners are husband and wife. They reside in Ridgewood, N.J. They filed a joint income tax return for the calendar year 1960 with the district director of internal revenue at Newark, N.J. George J. Becker will be referred to as the…
2Cases cited8 opinions
- Scott-Burr Stores Corp. v. WilcoxCourt of Appeals for the Fifth Circuit · 1952
- Sullivan v. CommissionerUnited States Tax Court · 1948
- Swenson v. CommissionerUnited States Tax Court · 1961
- Hooper v. CommissionerUnited States Board of Tax Appeals · 1932
- Estate of Ogsbury v. CommissionerUnited States Tax Court · 1957
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3Cited by4 opinions
- George J. Becker and Isabelle Becker v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
- Rolfs v. CommissionerUnited States Tax Court · 1972
- Becker v. CommissionerUnited States Tax Court · 1966
- Rolfs v. CommissionerUnited States Tax Court · 1972