Mason v. Commissioner
United States Board of Tax Appeals
Where a taxpayer enters into a contract of employment providing, together with other compensation, a bonus, measured in money, computed upon net earnings of the employer, and an inseparable provision of that same contract obligates the taxpayer to exchange such money, concurrently with its receipt, for stock of the employing company at a fixed value, held, the taxpayer realizes taxable income in the amount of the fair market value of such stock when he receives it.
1Opinion of the Court
*1288OPINION.
Leech:
Respondent determined a deficiency of $10,827.57 in petitioners’ income tax for the calendar year 1935. The issue presented is the propriety of the action of respondent in including in income an amount representing the fair market value of certain stock acquired by the petitioner, George W. Mason, in the taxable year.
The facts are stipulated. Petitioners are husband and wife and filed a joint return for the taxable year. The word “petitioner”, as hereinafter used, will refer to the petitioner, George W. Mason. On September 7, 1933, the petitioner entered into the following…
2Cited by3 opinions
- Mason v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Bronson v. CommissionerUnited States Tax Court · 1948
- Mason v. CommissionerUnited States Board of Tax Appeals · 1940