Adair v. Commissioner
United States Tax Court
In T.C. Memo. 1985-392, it was determined that stock received by petitioners in docket No. 3881-79 pursuant to the exercise of an option is ordinary income to the extent of the excess of the fair market value over the amount paid for the stock. It was also determined that the entire amount of stock received by petitioners in docket No. 9235-79 is subject to the imputed interest rules of sec. 483. Held: Fair market value of such stock determined as of the applicable dates.
1Opinion of the Court
WILLIAM O. ADAIR AND FLORENCE O. ADAIR, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Adair v. Commissioner
Docket Nos. 3881-79; 9235-79; 22777-81; 22778-81.
United States Tax Court
T.C. Memo 1987-494; 1987 Tax Ct. Memo LEXIS 491; 54 T.C.M. (CCH) 705; T.C.M. (RIA) 87494;
September 28, 1987.
In T.C. Memo. 1985-392, it was determined that stock received by petitioners in docket No. 3881-79 pursuant to the exercise of an option is ordinary income to the extent of the excess of the fair market value over the amount paid for the stock. It was also determined that the entire…
2Cases cited21 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. CartwrightSupreme Court of the United States · 1973
- Parker v. CommissionerUnited States Tax Court · 1986
- Messing v. CommissionerUnited States Tax Court · 1967
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
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