Legal Opinion
Harrison v. United States
District Court, E.D. Pennsylvania
Decided July 24, 1979No. Civ. A. 78-1576PublishedCited by 12 opinions
1Opinion of the Court
OPINION
LUONGO, District Judge.
Section 57(a)(6) of the Internal Revenue Code 1 provides that with respect to stock transferred pursuant to the exercise of a qualified or a restricted stock option, “the amount by which the fair market value of the share at the time of exercise exceeds the option price” constitutes an item of tax preference subject to the minimum tax under § 56. Section 1.57-l(f)(3) of the Treasury Regulations, first proposed on December 30, 1970, see 35 Fed.Reg. 19757 (1970), and finally adopted on September 12, 1978, see 43 Fed.Reg. 40459 (1978), throws some light on “fair…
2Cases cited18 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- United States v. CartwrightSupreme Court of the United States · 1973
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- Union Pacific Railroad Company v. The United StatesUnited States Court of Claims · 1968
13 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Jackie L. And Janet G. McDonald v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1985
- Aaron L. Kolom and Serita Kolom v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
- Gresham v. CommissionerUnited States Tax Court · 1982
- Estate of Gresham v. CommissionerCourt of Appeals for the Tenth Circuit · 1985
- Eastern Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1981
7 more not listed; retrieve them via the Exa API.