Lighthill v. Commissioner
United States Tax Court
One of petitioners in 1967 acquired through his employment a nonstatutory stock option which he exercised on June 10, 1968, acquiring stock restricted as to sale. The restrictions were removed on Mar. 14, 1969, and on Mar. 19, 1969, petitioner sold one-third of the stock.
Read the full summary
One of petitioners in 1967 acquired through his employment a nonstatutory stock option which he exercised on June 10, 1968, acquiring stock restricted as to sale. The restrictions were removed on Mar. 14, 1969, and on Mar. 19, 1969, petitioner sold one-third of the stock. Held: Petitioners realized ordinary income from services on Mar. 14, 1969, when the restriction on sale of the stock ended in the amount of the difference between the fair market value of the stock without restrictions as to sale as of June 10, 1968, and the cost of the stock. In computing capital gain on sale of the stock…
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the calendar year 1969 in the amount of $35,775.
The issues for decision are (1) whether petitioners realized income in 1969 on the lapse of restrictions on stock which one of them had acquired in 1968 under an option received in a prior year and if so the amount of income realized, and (2) the amount of capital gain petitioners realized later in 1969 upon the sale of one-third of that stock.
All of the facts have been stipulated and are found accordingly.
Petitioners, husband and wife, who resided in…
2Cases cited11 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Edgar v. CommissionerUnited States Tax Court · 1971
- Lehman v. CommissionerUnited States Tax Court · 1951
- United States v. William D. Frazell and Martha T. FrazellCourt of Appeals for the Fifth Circuit · 1964
6 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Apple Computer, Inc. v. CommissionerUnited States Tax Court · 1992
- Apple Computer, Inc. v. CommissionerUnited States Tax Court · 1992
- Lighthill v. CommissionerUnited States Tax Court · 1976