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ESTATE OF OGSBURY v. COMMISSIONER

Docket No. 52837.

28 T.C. 93 (1957)

ESTATE OF JAMES S. OGSBURY, DECEASED, FLORENCE N. OGSBURY, EXECUTRIX, AND FLORENCE N. OGSBURY, SURVIVING WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 22, 1957.

Attorney(s) appearing for the Case

Harman Hawkins, Esq., for the petitioner.

Ellyne E. Strickland, Esq., and A. Jesse Duke, Jr., Esq., for the respondent.

The Commissioner determined a deficiency in petitioners' income tax for the year 1948 in the amount of $68,860.56. The issues for decision are (1) whether the employee petitioner received compensation in connection with a stock option in 1948 when he paid for and received title to the stock, or in an earlier taxable year when the option was exercised, and (2) if the petitioner received compensation in 1948, what was the fair market value of the stock so received on December...

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