Robinson v. Commissioner
United States Tax Court
Held, date of grant of nonqualified employee stock option determined to be subsequent to Apr. 22, 1969, the effective date of sec. 83, I.R.C. 1954. Held, further, the compensation element in the option was taxable in year of exercise.
1Opinion of the Court
Prentice I. Robinson and Rosalie Robinson, Petitioners v. Commissioner of Internal Revenue, Respondent; Centronics Data Computer Corp. and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent
Robinson v. Commissioner
Docket Nos. 18038-80, 2951-82
United States Tax Court
82 T.C. 444; 1984 U.S. Tax Ct. LEXIS 96; 82 T.C. No. 32;
March 13, 1984, Filed
Held, date of grant of nonqualified employee stock option determined to be subsequent to Apr. 22, 1969, the effective date of sec. 83, I.R.C. 1954. Held, further, the compensation element in the option was taxable in year of exercise.
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2Cases cited30 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Rogers v. Guaranty Trust Co.Supreme Court of the United States · 1933
- Kerbs v. California Eastern Airways, Inc.Supreme Court of Delaware · 1952
- Gottlieb v. Heyden Chemical Corp.Supreme Court of Delaware · 1952
- Beard v. ElsterSupreme Court of Delaware · 1960
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