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SWENSON v. COMMISSIONER

Docket No. 81911.

37 T.C. 124 (1961)

GEORGE W. S. SWENSON AND RUTH E. SWENSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 31, 1961.

Attorney(s) appearing for the Case

J. Neil Morton, Esq., and John M. Sullivan, Esq., for the petitioners.

Leonard A. Hammes, Jr., Esq., for the respondent.

TRAIN, Judge.

Respondent determined a deficiency in petitioners' income tax for the calendar year 1957 in the amount of $14,607.86.

The issues for decision are:

(1) Whether George W. S. Swenson realized compensation income on the disposition of stock acquired under an employee stock option plan by disposing of the stock within 6 months after the transfer of such stock to him; and

(2) Whether George W. S. Swenson realized a short-term...

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