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ESTATE OF PAULINE v. COMMISSIONER

Docket No. 7258-65.

49 T.C. 263 (1967)

ESTATE OF PAULINE E. NOCK, DECEASED, BARBARA ANN LYTLE, ADMINISTRATRIX, WITH WILL ANNEXED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 26, 1967.

Attorney(s) appearing for the Case

Robert N. Dineen, for the petitioner.

Donald H. Richards, for the respondent.

HOYT, Judge:

Respondent determined a deficiency in income tax of Pauline E. Nock for the calendar year 1961 in the amount of $35,721.27. The principal issue to be decided is whether or not Pauline E. Nock realized and was required to recognize ordinary income when she exercised a restricted stock option in 1961 which she acquired by bequest from her deceased husband. If so, the correct amount of the gain must be determined also. Various adjustments with respect...

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