Kadillak v. Comm'r
United States Tax Court
P, as a sales assistant with Ariba Technologies, Inc. (Ariba), received incentive stock options (ISOs) subject to an employment termination restriction, whereby Ariba had the right to repurchase nonvested stock on the date of termination for its exercise price. On Apr. 5, 2000, P exercised his ISOs and was transferred all vested stock. The nonvested stock was placed in escrow and transferred to P as the shares vested on a monthly basis over 4 years.
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P, as a sales assistant with Ariba Technologies, Inc. (Ariba), received incentive stock options (ISOs) subject to an employment termination restriction, whereby Ariba had the right to repurchase nonvested stock on the date of termination for its exercise price. On Apr. 5, 2000, P exercised his ISOs and was transferred all vested stock. The nonvested stock was placed in escrow and transferred to P as the shares vested on a monthly basis over 4 years. P timely filed a sec. 83(b), I.R.C., election in May 2000 for the exercised ISOs. P's employment with Ariba was terminated on Apr. 4, 2001. Ariba…
1Opinion of the Court
ANTHONY J. KADILLAK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kadillak v. Comm'r
No. 2860-04L
United States Tax Court
127 T.C. 184; 2006 U.S. Tax Ct. LEXIS 34; 127 T.C. No. 13;
November 7, 2006, Filed
P, as a sales assistant with Ariba Technologies, Inc. (Ariba),
received incentive stock options (ISOs) subject to an employment
termination restriction, whereby Ariba had the right to
repurchase nonvested stock on the date of termination for its
exercise price. On Apr. 5, 2000, P exercised his ISOs and was
transferred all vested stock. The nonvested stock was placed in
escrow and…
2Cases cited17 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Montgomery v. Comm'rUnited States Tax Court · 2004
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Speltz v. Comm'rUnited States Tax Court · 2005
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