Summary
Issue was whether the property received by the taxpayer was stock aquired in a closely held company or the contract to acquire the stock at a later time.
See Also
Effective Date of Critical to Valuation of Stock
This case involves a claim by the Commissioner that taxpayer is liable for income tax on the difference between the price paid for stock and its fair market value under § 83(a) of the Internal Revenue Code.
Theophilos v. Commissioner
At issue in this case was whether the taxpayer acquired a beneficial interest in the closely held corporation of his former employer and whether full value was paid for the 40% minority interest in nonvoting common stock.