Slater v. Commissioner
United States Tax Court
In order to be released from a covenant not to compete, the petitioner transferred to his former employer certain rights in stock that he had acquired from such employer at a bargain price. At the time of the transfer, the value of the stock had declined greatly and was substantially less than the petitioner's basis in the stock. It was subsequently sold at a loss by a bank to satisfy a debt the petitioner owed the bank.
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In order to be released from a covenant not to compete, the petitioner transferred to his former employer certain rights in stock that he had acquired from such employer at a bargain price. At the time of the transfer, the value of the stock had declined greatly and was substantially less than the petitioner's basis in the stock. It was subsequently sold at a loss by a bank to satisfy a debt the petitioner owed the bank. Held, the loss was not an expense of seeking new employment. Sec. 162(a), I.R.C. 1954. Held, further, the sale was not integrally related to the bargain purchase of the…
1Opinion of the Court
Bertram H. Slater and Linda Gay Slater, Petitioners v. Commissioner of Internal Revenue, Respondent
Slater v. Commissioner
Docket No. 4068-73
United States Tax Court
64 T.C. 571; 1975 U.S. Tax Ct. LEXIS 112;
July 16, 1975, Filed
Decision will be entered for the respondent.
In order to be released from a covenant not to compete, the petitioner transferred to his former employer certain rights in stock that he had acquired from such employer at a bargain price. At the time of the transfer, the value of the stock had declined greatly and was substantially less than the petitioner's basis in the stock.…
2Cases cited6 opinions
- Primuth v. CommissionerUnited States Tax Court · 1970
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Cremona v. CommissionerUnited States Tax Court · 1972
- George T. And Ruth A. Kimbell v. United States of America, No. 73-3411 Summary Calendar. Rule 18, 5th Cir. See Isbell Enterprises, Inc. v. Citizens Casualty Co. Of New York, 5th Cir. 1970, 431 F.2d 409, Part ICourt of Appeals for the Fifth Circuit · 1974
- Turco v. CommissionerUnited States Tax Court · 1969
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