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Robinson v. Commissioner of Internal Revenue
Citation:
805 F.2d 38 (1986)Facts
Prentice Robinson received stock options as part of his employment package when he joined Centronics Data Computer Corporation in 1969. The stock option agreement contained a sellback provision requiring Robinson to sell his shares back to Centronics at his original cost if he wished to dispose of them within one year of exercising the option. Additionally, the stock certificates carried a restrictive legend regarding registration under the Securities Act of 1933, and Centronics placed a stop transfer order with its transfer agent. Robinson exercised his option on March 4, 1974. The IRS determined that Robinson should have recognized income from the stock option in 1974, while Robinson contended that the income was not recognizable until 1975 when the restrictions lapsed.
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