Swenson v. Commissioner
United States Tax Court
Holding Period. -- Sec. 421, Sec. 1222(3), I.R.C. 1954. -- On January 10, 1957, petitioner exercised his option to purchase 1,000 shares of Minnesota Mining and Manufacturing Company stock. The option provided that petitioner would have no rights of a stockholder and would have no interest in the shares until the certificates were issued.
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Holding Period. -- Sec. 421, Sec. 1222(3), I.R.C. 1954. -- On January 10, 1957, petitioner exercised his option to purchase 1,000 shares of Minnesota Mining and Manufacturing Company stock. The option provided that petitioner would have no rights of a stockholder and would have no interest in the shares until the certificates were issued. The certificates were issued to petitioner on January 16, 1957. On July 16, 1957, petitioner sold 700 shares on the New York Stock Exchange. Held, petitioner's holding period began January 16, 1957, and ended July 16, 1957; therefore, petitioner did not hold…
1Opinion of the Court
George W. S. Swenson and Ruth E. Swenson, Petitioners, v. Commissioner of Internal Revenue, Respondent
Swenson v. Commissioner
Docket No. 81911
United States Tax Court
37 T.C. 124; 1961 U.S. Tax Ct. LEXIS 43;
October 31, 1961, Filed
Decision will be entered for the respondent.
Holding Period. -- Sec. 421, Sec. 1222(3), I.R.C. 1954. -- On January 10, 1957, petitioner exercised his option to purchase 1,000 shares of Minnesota Mining and Manufacturing Company stock. The option provided that petitioner would have no rights of a stockholder and would have no interest in the shares until the certificates…
2Cases cited30 opinions
- Tyler v. United StatesSupreme Court of the United States · 1930
- Helvering v. San Joaquin Fruit & Investment Co.Supreme Court of the United States · 1936
- McFeely v. CommissionerSupreme Court of the United States · 1935
- Warburton v. WhiteSupreme Court of the United States · 1900
- First National Bank v. Gustin Minerva Consolidated Mining Co.Supreme Court of Minnesota · 1890
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