Legal Opinion

Weigl v. Commissioner

United States Tax Court

Decided May 30, 1985No. Docket Nos. 1707-73, 1709-73, 1726-73, 1817-73, 1827-73, 3430-73, 3431-73, 953-74, 8098-76Published

In 1965 through 1967, H.L. Federman & Co. underwrote the issuance of securities for certain companies for which it received commissions ranging from $ 13,624 to $ 75,000. At the time of each of the underwritings, H.L. Federman & Co. also received nonqualified options or warrants to purchase stock or other securities of the companies whose securities it was underwriting. The warrants were not traded on an established securities market.

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In 1965 through 1967, H.L. Federman & Co. underwrote the issuance of securities for certain companies for which it received commissions ranging from $ 13,624 to $ 75,000. At the time of each of the underwritings, H.L. Federman & Co. also received nonqualified options or warrants to purchase stock or other securities of the companies whose securities it was underwriting. The warrants were not traded on an established securities market. They were subject to various restrictions on transferability and generally were not exercisable for a certain period of time. Sometime after H.L. Federman & Co.…

1Opinion of the Court

Louis A. and Alice A. Weigl, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Weigl v. Commissioner

Docket Nos. 1707-73, 1709-73, 1726-73, 1817-73, 1827-73, 3430-73, 3431-73, 953-74, 8098-76

United States Tax Court

84 T.C. 1192; 1985 U.S. Tax Ct. LEXIS 72; 84 T.C. No. 66;

May 30, 1985. May 30, 1985, Filed

In 1965 through 1967, H.L. Federman & Co. underwrote the issuance of securities for certain companies for which it received commissions ranging from $ 13,624 to $ 75,000. At the time of each of the underwritings, H.L. Federman & Co. also received nonqualified options or…

Also in this document: Dissent.

2Cases cited53 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  3. Bixby v. CommissionerUnited States Tax Court · 1972
  4. United States v. CorrellSupreme Court of the United States · 1967
  5. Bingler v. JohnsonSupreme Court of the United States · 1969

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