Nock v. Commissioner

49 T.C. 263, 1967 U.S. Tax Ct. LEXIS 4
CourtUnited States Tax Court
DecidedDecember 26, 1967
DocketDocket No. 7258-65
StatusPublished
Cited by1 cases

This text of 49 T.C. 263 (Nock v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nock v. Commissioner, 49 T.C. 263, 1967 U.S. Tax Ct. LEXIS 4 (tax 1967).

Opinions

OPINION

The parties are not in complete agreement as to the issues presented but they are agreed that the principal issue should be determined by deciding whether or not John S. Nock would have been required to recognize ordinary income if he had exercised his restricted stock option on the date of his death, December 1, 1960. If on that day he could not have qualified for the no-income treatment provided for by subsection 421(a) of the Internal Revenue Code of 1954,1 then his widow, Pauline, could not so qualify.

At the date of his death on December 1,1960, John held an unexer-cised restricted stock option to purchase 1,000 shares of United States Steel common stock at $18.50 a share. Under section 421(d) (6) a person who acquires a restricted stock option by inheritance or bequest is afforded the same tax treatment upon its exercise as the deceased employee; it is undisputed that Pauline, John’s widow, qualifies for this identical treatment under section 421(d) (6). The principal issue here is therefore controlled by the provisions of section 421 as it existed in 1961 when the stock option here involved was exercised by Pauline after John’s death.

By the Revenue Act of 1950, Congress added new section 130A to the 1939 Code affording special no-income treatment for exercising employee incentive stock options under certain limited conditions if they met the definition of “a restricted stock option.”2 The legislative history indicates that the beneficial provisions were to apply if the restricted option were exercised while the grantee was still an employee of the granting employer or within a period of 3 months following termination of his employment. S. Rept. No. 2375, 81st Cong., 2d Sess. (1950), 1950-2 C.B. 526; H. Rept. No. 3124, 81st Cong., 2d Sess. (1950), 1950-2 C.B. 586. This provision was reenacted without substantial change as section 421 of the 1954 Code, with the addition of a paragraph (6) to subsection (d), and as effective in 1961 the pertinent portions are set forth below.8 The statute specifically excludes application of the relief afforded if the optionee is not an employee of the corporation which granted the option at the time of its exercise unless he exercises it “within 3 months after the date he ceases to be an employee” of such corporation. Section 421(d) (6) (A) then extends the relief from taxability after death of an employee to persons who acquire restricted stock options by bequest “to the same extent as if the option had been exercised by the decedent” eliminating the employment requirements of subsection (a).

Paragraph (6) of subsection (d) of section 421 was added by the 1954 Code and the legislative intent is set forth in H. Rept. No. 1337, to accompany H.R. 8300 (Pub. L. 591), 83d Cong., 2d Sess. (1954), as follows:

Under present law the tax treatment oí the exercise of a “restricted stock option” after the death of an employee is not provided for even though “restricted stock options” are transferable by will. Tour committee believes tbat tbe untimely death of an employee should not penalize his estate or beneficiaries by denying-an option the status of a “restricted stock option” merely because of the employee’s death. Por that reason the bill provides that the exercise of “restricted' stock options” by the estate or beneficiary of a deceased employee is to have the-same tax effect as if the employee had exercised the option. * * *

The petitioner insists that Nock could, have exercised the option on-December 1, 1960, and reaped the benefits of section 421 at that time,, whereas respondent insists that he could not. Petitioner urges us to conclude that Nock ceased to be an employee of United States Steel on September 1, 1960; that that day should not be counted in computing-the 3-month period specified in section 421, and that therefore on December 1,1960, Nock could have exercised his restricted stock option and obtained the no-income treatment afforded employees who exercise such options “within 3 months after the date” they cease to be employees. We agree with petitioner.

Although Nock’s applications for pensions requested that he be retired on August 31, 1960, instead of September 1, 1960, this was merely to comply with the pension fund rules specifying that the first installment of any pension granted under United States Steel’s pension fund shall be payable for the first full calendar month following the month in which retirement occurs. To conform to the already typed portion of the application indicating his retirement date as August 31, 1960, and to make sure that his pensions would begin when his wages-stopped, the retirement date was specified as August 31, 1960. However, it was specified repeatedly that Nock would be paid through August 31,1960, and that his employment would continue through that date. We conclude and hold that he was an employee of United States Steel through August 31, 1960, and ceased to be such an employee on> the following day, September 1,1960.

The parties agree and we concur that under the proper rule to be applied in computing the 3-month period specified by section 421, the day upon which Nock ceased to be an employee is to be excluded and the last day of the 3-month period is to be included. Sheets v. Selden’s Lessee, 2 Wall. 177, 190 (1864); Harriet M. Hooper, 26 B.T.A. 758 (1932), Rev. Rul. 66-5, 1966-1 C.B. 91. Excluding September 1,1960, and including December 1, 1960, the day of Nock’s death, it is clear and we hold that Nock’s right to benefit by the no-income treatment afforded by section 421 had not expired on December 1, 1960, the end of 3 months after the date he ceased to he an employee of United States Steel. As we interpret the statutory requirement Nock could have exercised his option on August 31, 1960, the day through which he was employed by United States Steel or at any time within 3 months after September 1,1960, the date he ceased being such an employee. On the day that he died, December 1, 1960, he still could have exercised the option and qualified for section 421 treatment.

Respondent contends that under his regulations, sections 1.421-3 (b) (1) and 1.421-5 (d) (1), an optionee must be a bona fide employee of the granting corporation at the time he exercises the option or within 3 months prior thereto, and in the case of a legatee that the optionee must have been an employee “at the time of his death or within three months before such time.” Applying this analysis of the regulations to the facts of the instant case, he asserts that Nock was not an employee of United States Steel on the date of his death, December 1,1960, nor had he been such an employee within the 3 months immediately before that date.

Petitioner candidly admits that if the strict and exact language of the regulations is applied without reference to the statutory language itself, Nock would be deprived of section 421 treatment as of the date of his death, and likewise his widow would not qualify for the no-income benefit of 421. Petitioner argues that the legislative history and the statutory language itself should control and the regulations be construed in harmony therewith; that the law does not require that an optionee be an employee within the 3-month period before the option is exercised; and that the sole statutory requirement is that the option be exercised within 3 months after the employee ceases to be employed by the granting corporation.

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Related

Nock v. Commissioner
49 T.C. 263 (U.S. Tax Court, 1967)

Cite This Page — Counsel Stack

Bluebook (online)
49 T.C. 263, 1967 U.S. Tax Ct. LEXIS 4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nock-v-commissioner-tax-1967.