Sorensen v. Commissioner
United States Tax Court
1. Following his retirement from the employment of Ford Motor Company, of which for a number of years he had been executive vice president at a salary of $ 250,000 a year, and after several approaches by officials of Willys-Overland Motors, Inc., and after his investigation into the affairs of Willys and its postwar prospects, the petitioner, in June 1944, entered into an arrangement with Willys whereby the latter employed him for a period of 10 years.
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1. Following his retirement from the employment of Ford Motor Company, of which for a number of years he had been executive vice president at a salary of $ 250,000 a year, and after several approaches by officials of Willys-Overland Motors, Inc., and after his investigation into the affairs of Willys and its postwar prospects, the petitioner, in June 1944, entered into an arrangement with Willys whereby the latter employed him for a period of 10 years. Under the arrangement the petitioner agreed that during his employment he would not act as an officer or director of any corporation, other…
1Opinion of the Court
OPINION.
Withey, Judge:
The first question for determination is whether the options granted to petitioner by Willys were given for the purpose of enabling petitioner to acquire a proprietary interest in that company or were given as compensation. The petitioner contends that they were given for the former purpose while the respondent urges that they were for the latter. The question is one of fact, Abraham Rosenberg, 20 T. C. 5, and has been resolved against the petitioner by our finding that the options were granted to him as compensation.
At the outset we are faced with the situation where a…
2Cases cited7 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Commissioner v. SmithSupreme Court of the United States · 1945
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
- Fisher v. CommissionerUnited States Tax Court · 1952
- Van Dusen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1948
2 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Simon Jaglom and Marie Jaglom v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Mingo v. CommissionerCourt of Appeals for the Fifth Circuit · 2014
- Lori M. & John M. Mingo v. CommissionerUnited States Tax Court · 2013
- Roberts v. CommissionerUnited States Tax Court · 1983
- Sorensen v. CommissionerUnited States Tax Court · 1954