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JONATHAN LOGAN, INC. v. COMMISSIONER

Docket Nos. 8218-72, 8284-72.

33 T.C.M. 1045 (1974)

T.C. Memo. 1974-237

Jonathan Logan, Inc., Petitioner v. Commissioner. Irwin C. Guild and Bernice Guild, Petitioners v. Commissioner.

United States Tax Court.

Filed September 16, 1974.

Attorney(s) appearing for the Case

James S. Eustice, 1345 Ave. of the Americas, New York, N.Y., and Stephen D. Gardner, for the petitioner in docket No. 8218-72. Elias Rosenzwieg, for the petitioners in docket No. 8284-72. George J. Mendelson, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined a deficiency in the income tax for 1967 of petitioner Jonathan Logan, Inc. in the amount of $230,994.78 and in the income tax for 1967 of petitioners Irwin C. Guild and Bernice Guild in the amount of $161,458.79. The issues are:

(1) Whether petitioner Guild received common stock from Logan as the result of an exercise of a restricted stock option as described in section 424...

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