Rolfs v. Commissioner
United States Tax Court
On Apr. 30, 1964, Rolfs and Arnold exercised statutory restricted stock options by giving their interest-bearing promissory notes for the purchase of a specified number of shares of stock of their employer, GB&B, pursuant to the latter's 1963 Employees' Stock Purchase Plan. Under the plan, cash payment had to be completed or a promissory note taken up no later than June 30, 1965, as a condition of the issuance of shares.
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On Apr. 30, 1964, Rolfs and Arnold exercised statutory restricted stock options by giving their interest-bearing promissory notes for the purchase of a specified number of shares of stock of their employer, GB&B, pursuant to the latter's 1963 Employees' Stock Purchase Plan. Under the plan, cash payment had to be completed or a promissory note taken up no later than June 30, 1965, as a condition of the issuance of shares. Rolfs and Arnold took up their notes respectively on May 1 and June 30 of 1965. On Oct. 14, 1965, they sold all their GB&B stock. Held, each sale was a disqualifying…
1Opinion of the Court
John H. Rolfs, Petitioner v. Commissioner of Internal Revenue, Respondent; Maxwell A. Arnold, Jr., and Patricia Arnold, Petitioners v. Commissioner of Internal Revenue, Respondent
Rolfs v. Commissioner
Docket Nos. 5618-70, 5708-70
United States Tax Court
58 T.C. 360; 1972 U.S. Tax Ct. LEXIS 118;
May 22, 1972, Filed
Decisions will be entered for the respondent.
On Apr. 30, 1964, Rolfs and Arnold exercised statutory restricted stock options by giving their interest-bearing promissory notes for the purchase of a specified number of shares of stock of their employer, GB&B, pursuant to the latter's 1963…
2Cases cited10 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Merrill v. CommissionerUnited States Tax Court · 1963
- Pike v. CommissionerUnited States Tax Court · 1965
- Weir v. CommissionerUnited States Tax Court · 1948
- George W. S. Swenson and Ruth E. Swenson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
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