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Commissioner v. Smith, 324 U.S. 177 (1945)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Commissioner v. Smith, 324 U.S. 177 (1945)
Commissioner of Internal Revenue v. Smith No. 371 Argued January 30, 31, 1945 Decided February 26, 1945 324 U.S. 177
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE NINTH CIRCUIT
Syllabus
An employer gave to its employee as compensation for his services an option to purchase shares of stock at a price not less than the then value of the stock. The option had no value at that time, and the compensation contemplated by the parties was the transfer to the employee of the shares of stock after their value had increased to more than the option price.
Held, under § 22(a) of the Revenue Act of 1938 and of the Internal Revenue Code, the employee received "compensation for personal service," and hence taxable income in each year in which stock was acquired, through effective exercise of the option in that year, in the amount of the difference between the pt.ion price and the then market value of the stock. P. 181.
142 F.2d 818, reversed.
Certiorari, 323 U.S. 696, to review the reversal of a decision of the Tax Court which sustained the Commissioner’s determination of a deficiency in income tax.
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Chicago: U.S. Supreme Court, "Syllabus," Commissioner v. Smith, 324 U.S. 177 (1945) in 324 U.S. 177 Original Sources, accessed November 25, 2024, http://originalsources.com/Document.aspx?DocID=HWB51WMCE9VPKDH.
MLA: U.S. Supreme Court. "Syllabus." Commissioner v. Smith, 324 U.S. 177 (1945), in 324 U.S. 177, Original Sources. 25 Nov. 2024. http://originalsources.com/Document.aspx?DocID=HWB51WMCE9VPKDH.
Harvard: U.S. Supreme Court, 'Syllabus' in Commissioner v. Smith, 324 U.S. 177 (1945). cited in 1945, 324 U.S. 177. Original Sources, retrieved 25 November 2024, from http://originalsources.com/Document.aspx?DocID=HWB51WMCE9VPKDH.
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