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PAGEL, INC. v. C.I.R.

No. 89-1016.

905 F.2d 1190 (1990)

PAGEL, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided June 15, 1990.

Attorney(s) appearing for the Case

John W. Lundquist, Minneapolis, Minn., for appellant.

Nancy G. Morgan, Washington, D.C., for appellee.

Before FAGG, Circuit Judge, HEANEY, Senior Circuit Judge, and BEAM, Circuit Judge.

FAGG, Circuit Judge.

Pagel, Inc. (Pagel) appeals from a United States Tax Court decision that income derived from Pagel's sale of a stock option was taxable as ordinary income under 26 U.S.C. § 83 (1976). We affirm.

Pagel received a nonqualified stock option in 1977 as partial compensation for underwriting a stock offering on behalf of Immuno Nuclear Corp. (Immuno). This option gave Pagel the right to buy Immuno shares at scheduled prices but restricted...

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