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, 8098-76PublishedCited by 10 opinions

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

Swift, Judge*:

Respondent determined deficiencies in and additions to petitioners’ Federal income tax liabilities as follows:

Sec. 6653(a)2

Docket No. Year Deficiency addition to tax

Louis A. Weigl 1707-73 $178.18 c— CD a*

and Alice A. Weigl 1,141.56 00 CD <y>

Joseph Mathes 1709-73 177.13 DCD 05

and Beatrice E. Mathes 1,645.06 00 CD 05

Walter C. Crawford 1726-73 1967 2,896.81

and Alice C. Crawford

H.L. Federman & Co., Inc. 1817-73 1966

1967

1968 1,445,483.79

Hyman L. Federman 1827-73 1965 163,241.88 $8,162.09

and Sylvia Federman 1966 2,272.59 113.63

1967 100,889.44

1968 637,530.87

8098-76 1969 98,643.98

Morris…

2Cases cited46 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

41 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. Pagel, Inc. v. CommissionerUnited States Tax Court · 1988
  2. Kimberlin v. Comm'rUnited States Tax Court · 2007
  3. Convergent Technologies v. CommissionerUnited States Tax Court · 1995
  4. AkersUnited States Tax Court · 1992
  5. Hoffman v. CommissionerUnited States Tax Court · 1989

5 more not listed; retrieve them via the Exa API.

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