Legal Opinion

Enos v. Commissioner

United States Tax Court

Decided October 21, 1958No. Docket No. 65059Published

The petitioner in 1947 received from his employer, E. W. Bliss Company, an option to purchase 25,000 shares of its unissued stock at a stated price. Petitioner subsequently purportedly assigned his rights thereunder to his wife and two daughters for a nominal consideration. In 1952 petitioner's wife and daughters surrendered the option rights to E. W. Bliss Company for $ 2 for each share covered thereby.

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The petitioner in 1947 received from his employer, E. W. Bliss Company, an option to purchase 25,000 shares of its unissued stock at a stated price. Petitioner subsequently purportedly assigned his rights thereunder to his wife and two daughters for a nominal consideration. In 1952 petitioner's wife and daughters surrendered the option rights to E. W. Bliss Company for $ 2 for each share covered thereby. Held, that the gain realized from the cancellation of the stock options constituted compensation taxable to petitioner in 1952.

1Opinion of the Court

Robert C. Enos and Clara M. Enos, Petitioners, v. Commissioner of Internal Revenue, Respondent

Enos v. Commissioner

Docket No. 65059

United States Tax Court

31 T.C. 100; 1958 U.S. Tax Ct. LEXIS 59;

October 21, 1958, Filed

Decision will be entered for the respondent.

The petitioner in 1947 received from his employer, E. W. Bliss Company, an option to purchase 25,000 shares of its unissued stock at a stated price. Petitioner subsequently purportedly assigned his rights thereunder to his wife and two daughters for a nominal consideration. In 1952 petitioner's wife and daughters surrendered the option…

2Cases cited12 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Helvering v. HorstSupreme Court of the United States · 1940
  3. Commissioner v. LoBueSupreme Court of the United States · 1956
  4. Helvering v. EubankSupreme Court of the United States · 1941
  5. Burnet v. LeiningerSupreme Court of the United States · 1932

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