Kast v. Commissioner
United States Tax Court
Each petitioner in 1976 exercised his option to purchase stock of his employer, K Corp., such option having been granted to him pursuant to a qualified stock option plan adopted by the employer. The option price was $ 7 per share; in 1976, at the time the options were exercised, the stock had a fair market value of $ 13.25 per share.
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Each petitioner in 1976 exercised his option to purchase stock of his employer, K Corp., such option having been granted to him pursuant to a qualified stock option plan adopted by the employer. The option price was $ 7 per share; in 1976, at the time the options were exercised, the stock had a fair market value of $ 13.25 per share. In 1977, K Corp. adopted a plan of liquidation and, pursuant to such liquidation, each petitioner as a shareholder in 1977 received a distribution of $ 15.30 per share and further distributions in 1978 and 1979. Each petitioner had voted against the adoption of…
1Opinion of the Court
OPINION
Scott, Judge:
On November 30,1981, petitioners in the case of Francis X. Kast and Anne E. Kast, docket No. 13643-81, filed a motion for summary judgment which was set for hearing at San Francisco, Calif., on March 8, 1982. When the case was called for hearing, respondent filed a motion to consolidate the remaining above-entitled cases with the Kast case and consider the motion as going to all the cases. There was no objection on the part of any of petitioners since the facts in all these cases are substantially the same. The parties also agree that the Court may accept the facts as set…
2Cases cited13 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- United States v. DavisSupreme Court of the United States · 1970
- Hotel Equities Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1976
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3Cited by7 opinions
- Shelton v. CommissionerUnited States Tax Court · 1995
- Warren H. Schumann and Maria T. Schumann v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1988
- Ebben v. CommissionerUnited States Tax Court · 1983
- JD Holdings, L.L.C.Court of Chancery of Delaware · 2014
- Kast v. CommissionerUnited States Tax Court · 1982
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