Legal Opinion

Putchat v. Commissioner

United States Tax Court

Decided June 18, 1969No. Docket No. 1896-64Published

Held, an amount received by petitioner as consideration for the release of all his rights under an employment contract, including the right to be employed as a project manager, the right to receive 20 percent of net profits, and the right to exercise a stock option, constitutes ordinary income.

1Opinion of the Court

Nathan Putchat and Sally Putchat, Petitioners v. Commissioner of Internal Revenue, Respondent

Putchat v. Commissioner

Docket No. 1896-64

United States Tax Court

52 T.C. 470; 1969 U.S. Tax Ct. LEXIS 109;

June 18, 1969, Filed

Decision will be entered for the respondent.

Held, an amount received by petitioner as consideration for the release of all his rights under an employment contract, including the right to be employed as a project manager, the right to receive 20 percent of net profits, and the right to exercise a stock option, constitutes ordinary income.

Robert B. Alexander, Jr., for the…

2Cases cited11 opinions

  1. Commissioner v. LoBueSupreme Court of the United States · 1956
  2. Commissioner v. SmithSupreme Court of the United States · 1945
  3. Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
  4. Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  5. Estate of Carter v. CommissionerUnited States Tax Court · 1960

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