Alves v. Commissioner
United States Tax Court
In 1970, Lawrence J. Alves purchased 40,000 shares of stock of a new corporation by which he became employed for the fair market value of the stock at the date of purchase. His employment agreement stated that one of the reasons for issuance of the stock was to provide the employee with additional interest in the company.
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In 1970, Lawrence J. Alves purchased 40,000 shares of stock of a new corporation by which he became employed for the fair market value of the stock at the date of purchase. His employment agreement stated that one of the reasons for issuance of the stock was to provide the employee with additional interest in the company. Two-thirds of the stock was restricted from being sold prior to the expiration of a stated period and, if the employee left the employ of the corporation prior to the expiration of that period, the company could repurchase the stock at the amount the employee paid for it.…
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined deficiencies in petitioners’ income tax for the calendar years 1974 and 1975 in the amounts of $12,335.53 and $3,822.77, respectively. By amendment to answer filed on September 24, 1980, respondent claimed an increased deficiency for the calendar year 1975 in the amount of $8,037.33, making a total claimed deficiency for that year of $11,860.10. By amendment to petition filed on June 15,1981, petitioners raised a new issue claiming that the cost basis to be assigned to the stock sold during 1974 and 1975 was incorrectly stated in their returns as…
2Cases cited7 opinions
- Lemmen v. CommissionerUnited States Tax Court · 1981
- Miriam Sakol v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1978
- Sakol v. CommissionerUnited States Tax Court · 1977
- Gresham v. CommissionerUnited States Tax Court · 1982
- Thomas R. Pledger and Phyllis R. Pledger v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
2 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Venture Funding v. CommissionerUnited States Tax Court · 1998
- Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
- Lawrence J. Alves and Myra L. Alves v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Bagley v. CommissionerUnited States Tax Court · 1985
- Cramer v. CommissionerUnited States Tax Court · 1993
22 more not listed; retrieve them via the Exa API.