Robinson v. Commissioner of Internal Revenue

HICKENLOOPER, Circuit Judge.

Petitioner entered the employment of the Libbey Glass Company in 1911 in a menial capacity. For several years he worked at no salary whatever or for a nominal salary, learning the business. By 1915 he had risen to a position of comparative importance, and had received an offer of employment by the Owens Bottle Company. He discussed this offer with Mr. E. D. Libbey, who had been his patron and adviser. Mr. Libbey advised against the acceptance of the offer, and proposed to “sell” to him 200 shares of common stock of the Libbey Company at a price of-$200 per share,…