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Robinson v. Commissioner of Internal Revenue

 805 F.2d 38 (1986)

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Robinson v. Commissioner of Internal Revenue

United States Court of Appeals for the First Circuit

 805 F.2d 38 (1986)

Facts

Prentice Robinson (plaintiff) received an option to buy stock, below market price, in Centronics Data Computer Corporation as part of his compensation package when he worked at Centronics. The option included a term that required Robinson to sell the shares back to Centronics at his original cost, should he want to dispose of the Centronics stock within one year of exercising the option. Robinson exercised the option in 1974. The Commissioner of Internal Revenue (the commissioner) (defendant) determined that that Robinson should pay income taxes on the shares in 1974—the year the option was exercised. Robinson appealed; however, the United States Tax Court upheld the commissioner’s position. Robinson appealed again, arguing that the sellback provisions of the option created a substantial risk of forfeiture and made the stock option nontransferable until 1975, one year after he exercised the option and purchased the Centronics stock. Robinson argued that his tax liability related to the Centronics shares should be determined in 1975, at the time the stock was no longer restricted by its sellback provisions.

Rule of Law

Issue

Holding and Reasoning (Torruella, J.)

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