Haberman v. Commissioner
United States Board of Tax Appeals
1. The taxpayer agreed with a corporation to remain in the employ of one of its subsidiaries for three years, beginning January 1, for a compensation consisting of a stated cash salary and the right to purchase a stated number of shares of the stock of the parent. Stock certificates for fully issued and paid-up shares were issued to the taxpayer and were immediately endorsed by him and deposited with the parent to secure a loan for the full purchase price of all the shares.
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1. The taxpayer agreed with a corporation to remain in the employ of one of its subsidiaries for three years, beginning January 1, for a compensation consisting of a stated cash salary and the right to purchase a stated number of shares of the stock of the parent. Stock certificates for fully issued and paid-up shares were issued to the taxpayer and were immediately endorsed by him and deposited with the parent to secure a loan for the full purchase price of all the shares. Upon payment of one third of the loan, with interest, on or before January 2 following each calendar year, the taxpayer…
1Opinion of the Court
OPINION.
Murdock:
The Commissioner determined deficiencies as follows:
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The parties have disposed of all issues save one which is common to all three proceedings. A stipulation of facts was filed.
Haberman was vice president and general counsel, and Collins was secretary, of the Commercial Investment Trust Incorporated at *76all times material hereto. That corporation was a subsidiary of the Commercial Investment Trust Corporation. Haberman, on June 1, 1926, entered into a, contract with Commercial Investment Trust Corporation, and the Commercial Investment Trust Incorporated joined in…
2Cases cited5 opinions
- Erskine v. CommissionerUnited States Board of Tax Appeals · 1932
- Burns v. CommissionerUnited States Board of Tax Appeals · 1934
- Henritze v. CommissionerUnited States Board of Tax Appeals · 1933
- Newman v. CommissionerUnited States Board of Tax Appeals · 1928
- Fesler v. CommissionerUnited States Board of Tax Appeals · 1928
3Cited by3 opinions
- Gadd v. CommissionerUnited States Tax Court · 1983
- Haberman v. CommissionerUnited States Board of Tax Appeals · 1934
- Rossheim v. CommissionerUnited States Board of Tax Appeals · 1934