Legal Opinion
Anthony Theophilos Patricia A. Theophilos v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided May 31, 1996No. 94-70634PublishedCited by 25 opinions
1Opinion of the Court
LAY, Circuit Judge:
This appeal is from a deficiency judgment rendered by the Tax Court. The Tax Court found that when the taxpayer 1 acquired stock in a closely held corporation on December 10, 1986, he incurred taxable income for the excess of the fair market value of the property over the amount paid for the property under § 83(a) of the Internal Revenue Code. 2 See Theophilos v. Commissioner, 67 T.C.M. (CCH) 2106, 1994 WL 31445 (1994). The taxpayer does not dispute he received property from his employer under § 83(a), but asserts he possessed a contract to acquire the stock in 1985 when he…
2Cases cited24 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Joseph R. Bolker v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Bazley v. CommissionerSupreme Court of the United States · 1947
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
19 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Stephen D. Pahl Louise A. Pahl v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- Rosa Shackleford, Personal Representative of the Estate of Thomas J. Shackleford, Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 2001
- Cook v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 2003
- Estate of Fred O. Godley, Deceased Fred D. Godley, Administrator Cta v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 2002
- Merlo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2007
20 more not listed; retrieve them via the Exa API.