Steiner v. Commissioner
United States Tax Court
In 1983 petitioner husbands (PHs), officers and directors of a corporation (VB), bought shares of VB "junior" common stock which were to "convert automatically" into regular VB common stock "upon the occurrence of" any one of four categories of performance goals or conditions, including certain net income goals of VB.
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In 1983 petitioner husbands (PHs), officers and directors of a corporation (VB), bought shares of VB "junior" common stock which were to "convert automatically" into regular VB common stock "upon the occurrence of" any one of four categories of performance goals or conditions, including certain net income goals of VB. PHs filed sec. 83(b), I.R.C. 1954, elections with respondent (R) to include any stock price bargain as income for 1983. VB met the net income goal for its fiscal year ending Dec. 28, 1984. In February or March 1985 an auditors' report confirmed the attainment of this goal.…
1Opinion of the Court
ALAN B. STEINER AND BARBARA W. STEINER, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Steiner v. Commissioner
Docket Nos. 27818-90, 27819-90, 27820-90, 27821-90, 27822-90, 27823-90, 27824-90, 27825-90
United States Tax Court
T.C. Memo 1995-122; 1995 Tax Ct. Memo LEXIS 118; 69 T.C.M. (CCH) 2176;
March 22, 1995, Filed
Appropriate orders will be issued granting petitioners' motions for leave to amend their petitions
In 1983 petitioner husbands (PHs), officers and directors of a corporation (VB), bought shares of VB "junior" common stock which were to "convert automatically" into…
2Cases cited57 opinions
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