Legal Opinion

Le Vant v. Commissioner

United States Tax Court

Decided November 29, 1965No. Docket No. 3893-63Published

In an employment agreement dated April 22, 1957, between petitioner and his employer, Edison Co., petitioner was granted an option to purchase a 20-percent interest in the business of Edison Co., or its successor, for $ 50,000, exercisable for a period of 2 years beginning on January 1, 1958. In a transaction whereby Colgate-Palmolive Co. acquired all the stock of Edison, Inc., successor to Edison Co., in exchange for stock of Colgate, petitioner transferred all of his…

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In an employment agreement dated April 22, 1957, between petitioner and his employer, Edison Co., petitioner was granted an option to purchase a 20-percent interest in the business of Edison Co., or its successor, for $ 50,000, exercisable for a period of 2 years beginning on January 1, 1958. In a transaction whereby Colgate-Palmolive Co. acquired all the stock of Edison, Inc., successor to Edison Co., in exchange for stock of Colgate, petitioner transferred all of his rights under the April 22, 1957, employment agreement, including the option, to Colgate in exchange for 6,494 shares of…

1Opinion of the Court

Jack I. LeVant and May LeVant, Petitioners, v. Commissioner of Internal Revenue, Respondent

Le Vant v. Commissioner

Docket No. 3893-63

United States Tax Court

45 T.C. 185; 1965 U.S. Tax Ct. LEXIS 13;

November 29, 1965, Filed

Decision will be entered under Rule 50.

In an employment agreement dated April 22, 1957, between petitioner and his employer, Edison Co., petitioner was granted an option to purchase a 20-percent interest in the business of Edison Co., or its successor, for $ 50,000, exercisable for a period of 2 years beginning on January 1, 1958. In a transaction whereby Colgate-Palmolive Co.…

2Cases cited15 opinions

  1. Commissioner v. LoBueSupreme Court of the United States · 1956
  2. Commissioner v. SmithSupreme Court of the United States · 1945
  3. Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
  4. Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
  5. June M. Carlberg, by Vida M. Frick, Guardian v. United StatesCourt of Appeals for the Eighth Circuit · 1960

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