Horwith v. Commissioner
United States Tax Court
In transfers governed by sec. 83(a), I.R.C. 1954, petitioners received Mattel stock. Petitioners were subject to the provisions of sec. 16(b), Securities Exchange Act of 1934, with respect to trading in Mattel stock.
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In transfers governed by sec. 83(a), I.R.C. 1954, petitioners received Mattel stock. Petitioners were subject to the provisions of sec. 16(b), Securities Exchange Act of 1934, with respect to trading in Mattel stock. Subsequent to the transfers, it became known that the true financial condition of Mattel had been concealed and misstated in prior years, including the dates when petitioners received their stock pursuant to sec. 83(a). Held, the trading prices of Mattel common stock on the New York Stock Exchange established the fair market value of the shares received by petitioners in spite of…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax for the taxable years 1971 and 1972 in the respective amounts of $1,371 and $12,400. Concessions having been made, the only issue remaining for our decision is whether petitioners properly valued certain stock received by them in 1972 for purposes of computing income under section 83(a)(1), I.R.C. 1954.1
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts, the additional stipulation of facts, and the exhibits attached to them are incorporated by this reference.
Petitioners…
2Cases cited9 opinions
- Kolom v. Comm'rUnited States Tax Court · 1978
- Miriam Sakol v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1978
- Sakol v. CommissionerUnited States Tax Court · 1977
- Frank v. CommissionerUnited States Tax Court · 1970
- M. P. Frank and Beatrice Frank v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1971
4 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Estate of Piper v. CommissionerUnited States Tax Court · 1979
- Bagley v. CommissionerUnited States Tax Court · 1985
- Strom v. United StatesCourt of Appeals for the Ninth Circuit · 2011
- Johnson v. CommissionerUnited States Tax Court · 1980
- Robinson v. CommissionerUnited States Tax Court · 1984
15 more not listed; retrieve them via the Exa API.