Bayley v. Commissioner
United States Tax Court
Petitioner held 5,000 shares of GRT stock issued to him for services to that corporation and pursuant to a permit of the California Commissioner of Corporations, which permit imposed restrictions that had a significant effect on the stock's value.
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Petitioner held 5,000 shares of GRT stock issued to him for services to that corporation and pursuant to a permit of the California Commissioner of Corporations, which permit imposed restrictions that had a significant effect on the stock's value. Held, petitioner's stock is stock subject to restrictions significantly affecting its value, rather than a second class of unrestricted stock, for purposes of secs. 1.61-2(d)(5) and 1.421-6(d)(2)(i), Income Tax Regs.Held, further, restrictions imposed by the Commissioner of Corporations pursuant to California securities laws, are "restrictions"…
1Opinion of the Court
Forrester, Judge:
Respondent has determined a deficiency in petitioners’ Federal income tax for the taxable year 1968 in the amount of $16,922.95. There are two issues for our decision: (1) Whether the stock issued to petitioner Alan J. Bayley in 1966 as compensation for promotional services was subject to restrictions which had a significant effect on its value; and, if so, (2) whether such restrictions were removed, or ceased to have a significant effect on such stock’s value during 1968.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners Alan J. and Barbara…
2Cases cited7 opinions
- Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
- Gamman v. CommissionerUnited States Tax Court · 1966
- 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
- Hirsch v. CommissionerUnited States Tax Court · 1968
2 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
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- Horwith v. CommissionerUnited States Tax Court · 1979
- Pledger v. CommissionerUnited States Tax Court · 1979
- Robinson v. CommissionerUnited States Tax Court · 1984
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