McLaine v. Commissioner
United States Tax Court
In 1999 P exercised nonqualified stock options (NQOs) previously issued to him by E, his recent employer, and simultaneously sold the option stock, receiving from E the sale proceeds, less the exercise price, undiminished by withheld income taxes. P reported the gain but did not pay the balance shown as due on his return. R issued a notice of intent to levy to collect the balance, interest, and additions to tax for failures to pay tax and estimated tax.
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In 1999 P exercised nonqualified stock options (NQOs) previously issued to him by E, his recent employer, and simultaneously sold the option stock, receiving from E the sale proceeds, less the exercise price, undiminished by withheld income taxes. P reported the gain but did not pay the balance shown as due on his return. R issued a notice of intent to levy to collect the balance, interest, and additions to tax for failures to pay tax and estimated tax. P had a collection due process hearing, and R's Appeals Office determined to proceed with collection. P challenges the determination…
1Opinion of the Court
JOHN J. MCLAINE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
McLaine v. Comm'r
Docket No. 15932-07L
United States Tax Court
138 T.C. 228; 2012 U.S. Tax Ct. LEXIS 11; 138 T.C. No. 10;
March 13, 2012, Filed
An appropriate order and decision will be entered.
In 1999 P exercised nonqualified stock options (NQOs) previously issued to him by E, his recent employer, and simultaneously sold the option stock, receiving from E the sale proceeds, less the exercise price, undiminished by withheld income taxes. P reported the gain but did not pay the balance shown as due on his return. R issued a…
Also in this document: Concurrence.
2Cases cited23 opinions
- Ashwander v. Tennessee Valley AuthoritySupreme Court of the United States · 1936
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Begier v. Internal Revenue ServiceSupreme Court of the United States · 1990
- Liverpool, New York & Philadelphia Steamship Co. v. Commissioners of EmigrationSupreme Court of the United States · 1885
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