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BAGLEY v. C.I.R.

No. 86-1396.

806 F.2d 169 (1986)

Hughes A. BAGLEY and Marilyn B. Bagley, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided November 25, 1986.

Rehearing Denied January 22, 1987.

Attorney(s) appearing for the Case

Sam S. Killinger, Sioux City, Iowa, for appellants.

Teresa E. McLaughlin, Washington, D.C., for appellee.

Before McMILLIAN and ARNOLD, Circuit Judges, and NICHOL, Senior District Judge.

PER CURIAM.

Hughes A. Bagley and Marilyn B. Bagley, husband and wife, appeal from a final judgment of the United States Tax Court,1 finding deficiencies in income tax due for the tax year 1978. For reversal appellants argue that (1) the stock option granted to Hughes Bagley was not compensation for services performed and thus the $70,000 paid to Bagley for the termination of the option was taxable as capital gains rather than as ordinary...

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