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BOWEN v. COMMISSIONER

Docket Nos. 35225, 35226.

13 T.C.M. 668 (1954)

T. C. Memo. 1954-101

Robert A. Bowen and Helen Bowen v. Commissioner. John D'Arcy, Jr. and Marian S. D'Arcy v. Commissioner.

United States Tax Court.

Filed July 22, 1954.

Attorney(s) appearing for the Case

Harry B. Sutter, Esq., One North LaSalle Street, Chicago, Ill., and Ralph E. Davis, Esq., for the petitioners. John L. Pedrick, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in income tax for 1949 in the amounts of $754.26 and $811.40 in Docket Nos. 35225 and 35226, respectively. The only question is whether petitioners Robert A. Bowen and John D'Arcy. Jr., realized taxable income in 1949 when each exercised an option to purchase stock from his employer corporation for less than the actual value of such stock.

Findings of Fact

The stipulation...

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