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BAGLEY v. COMMISSIONER

Docket No. 18838-82.

85 T.C. 663 (1985)

HUGHES A. BAGLEY AND MARILYN B. BAGLEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 30, 1985.

Attorney(s) appearing for the Case

Sam S. Killinger, for the petitioners.

J. Anthony Hoefer, for the respondent.

FAY, Judge:

Respondent determined a deficiency of $40,760 in petitioners' 1978 Federal income tax. The issues are (1) whether a payment received by petitioner Hughes A. Bagley from his employer in exchange for the termination of an employee stock option is taxable as capital gain or as ordinary income; and (2) whether a consulting fee received by petitioner Hughes A. Bagley is taxable to him or rather, to his wholly...

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