Montgomery v. Comm'r
United States Tax Court
P-H, president and CEO of MGC Communications, Inc. (MGC), received incentive stock options (ISOs) from MGC between April 1996 and March 1999. In November 1999, P-H resigned as president and CEO of MGC and entered into an employment contract with MGC which included provisions accelerating the vesting dates of his ISOs. In early 2000, P-H exercised many of his ISOs.
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P-H, president and CEO of MGC Communications, Inc. (MGC), received incentive stock options (ISOs) from MGC between April 1996 and March 1999. In November 1999, P-H resigned as president and CEO of MGC and entered into an employment contract with MGC which included provisions accelerating the vesting dates of his ISOs. In early 2000, P-H exercised many of his ISOs. P-H subsequently sold shares of MGC stock in 2000 and 2001 at prices above and below the exercise prices that he paid for the shares. Ps filed a joint Federal income tax return for 2000 reporting total tax of $ 2,831,360, including…
1Opinion of the Court
NIELD AND LINDA MONTGOMERY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Montgomery v. Comm'r
No. 633-05
United States Tax Court
127 T.C. 43; 2006 U.S. Tax Ct. LEXIS 23; 127 T.C. No. 3;
August 28, 2006, Filed
P-H, president and CEO of MGC Communications, Inc. (MGC),
received incentive stock options (ISOs) from MGC between April
1996 and March 1999. In November 1999, P-H resigned as president
and CEO of MGC and entered into an employment contract with MGC
which included provisions accelerating the vesting dates of his
ISOs. In early 2000, P-H exercised many of his ISOs. P-H
subsequently…
2Cases cited15 opinions
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Fed. Sec. L. Rep. P 90,216 Magma Power Company v. The Dow Chemical CompanyCourt of Appeals for the Second Circuit · 1998
- Allen v. Comm'rUnited States Tax Court · 2002
- Fed. Sec. L. Rep. P 90,280 Margaret Gwozdzinsky, Derivatively on Behalf of Revco D.S., Inc. v. Zell/chilmark Fund, L.P. And Revco D.S., Inc.Court of Appeals for the Second Circuit · 1998
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