RANK v. UNITED STATES

No. 21257.

345 F.2d 337 (1965)

Raymond A. RANK et al., Appellants, v. UNITED STATES of America, Appellee.

United States Court of Appeals Fifth Circuit.

May 4, 1965.


Attorney(s) appearing for the Case

William P. Fonville, Dallas, Tex., James F. Hoge, Jr., Fort Worth, Tex., for appellants.

Myron C. Brown, Atty., Dept. of Justice, Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Atty., Dept. of Justice, Washington, D. C., H. Barefoot Sanders, U. S. Atty., Dallas, Tex., David O. Walter, Michael I. Smith, Attys., Dept. of Justice, Washington D. C., for appellee.

Before TUTTLE, Chief Judge, and BROWN and GEWIN, Circuit Judges.


JOHN R. BROWN, Circuit Judge:

This case presents the question whether the gain received by the Taxpayer-Optionee on the assignment back to the Employer-Optioner of the unexercised option granted as a compensatory restricted stock option is taxable as capital gain when a transfer of the underlying stock at such time would have been a disqualifying disposition subjecting the proceeds to treatment as ordinary income. In rejecting the Taxpayer's appeal, we agree with...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases