Legal Opinion
Pagel, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided June 15, 1990No. 89-1016PublishedCited by 48 opinions
1Opinion of the Court
FAGG, Circuit Judge.
Pagel, Inc. (Pagel) appeals from a United States Tax Court decision that income derived from Pagel’s sale of a stock option was taxable as ordinary income under 26 U.S.C. § 83 (1976). We affirm.
Pagel received a nonqualified stock option in 1977 as partial compensation for underwriting a stock offering on behalf of Immuno Nuclear Corp. (Immuno). This option gave Pagel the right to buy Immuno shares at scheduled prices but restricted Pagel from exercising or disposing of the option for thirteen months after its grant. At the time of receipt, Immuno options were not publicly…
2Cases cited7 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- United States v. MortonSupreme Court of the United States · 1984
- Pagel, Inc. v. CommissionerUnited States Tax Court · 1988
2 more not listed; retrieve them via the Exa API.
3Cited by48 opinions
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1991
- Charles Hefti Marion Hefti v. Commissioner of Internal Revenue of the United States of AmericaCourt of Appeals for the Eighth Circuit · 1993
- Hefti v. CommissionerUnited States Tax Court · 1991
- Richard A. Cramer Alice D. Cramer Warren K. Boynton Susi M. Boynton Kevin P. Monaghan Dina A. Monaghan v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Custom Chrome, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
43 more not listed; retrieve them via the Exa API.