Kuchman v. Commissioner
United States Tax Court
Stock in the corporation employing petitioner and issued to him under an agreement restricting its use and sale held to have had no fair market value when acquired capable of being ascertained with reasonable certainty so as to justify charging petitioner with income at the time of issuance.
1Opinion of the Court
Harold H. Kuchman and Jennie F. Kuchman, Petitioners, v. Commissioner of Internal Revenue, Respondent
Kuchman v. Commissioner
Docket No. 29434
United States Tax Court
18 T.C. 154; 1952 U.S. Tax Ct. LEXIS 210;
April 30, 1952, Promulgated
Decision will be entered for the petitioners.
Stock in the corporation employing petitioner and issued to him under an agreement restricting its use and sale held to have had no fair market value when acquired capable of being ascertained with reasonable certainty so as to justify charging petitioner with income at the time of issuance.
Harry J. Rudick, Esq., Mason G.…
2Cases cited15 opinions
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- Commissioner v. SmithSupreme Court of the United States · 1945
- Heiner v. CrosbyCourt of Appeals for the Third Circuit · 1928
- Schuh Trading Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1938
- Lehman v. CommissionerUnited States Tax Court · 1951
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