Prentice I. Robinson v. Commissioner of Internal Revenue, Centronics Data Computer Corporation and Subsidiaries, Intervenor

TORRUELLA, Circuit Judge.

This appeal concerns the meaning of the timing provisions of Section 83 of the Internal Revenue Code, 26 U.S.C. § 83, which governs the taxation of property transferred in connection with a performance of services.

I. The Stock Option Agreement

Appellant Prentice Robinson held an option to purchase stock, at a below market price, in Centronics Data Computer Corp., a Delaware corporation with its principal place of business in New Hampshire. Robinson received the option as part of his employment package when he became a Centronics employee during the spring of 1969. 1

The…