Commissioner v. Smith, 324 U.S. 695 (1945)

Commissioner of Internal Revenue v. Smith


No. 371


Decided April 9, 1945
324 U.S. 695

ON PETITION FOR REHEARING

Syllabus

The conclusion of the Tax Court upon the facts of this case that the option to purchase stock was effectively exercised and taxable compensation was received, not when the optionee made his election and paid the option price, but when the shares were delivered to him, is supported by the record. P. 696.

Rehearing denied.

On petition for rehearing of Commissioner v. Smith, 324 U.S. 177.