- 13 - Federal income tax return for the cost of purchasing the options. However, Warner-Lambert reduced the offer for IMED from $480 million to $465 million. During the final negotiations, the officers and directors of IMED met with the law firm Skadden, Arps, Slate, Meagher & Flom (Skadden, Arps), which represented Warner-Lambert in New York City. After a meeting with the attorneys from Skadden, Arps in Manhattan, Monaghan informed Henry that he had structured the options as long-term capital gain. Subsequently, Monaghan told Boynton, in response to Boynton's question, that the option proceeds would be treated as long-term capital gain. On July 8, 1982, the Swiss trust that held the 1981 options was dissolved. The assets of the trust, the 1981 options, reverted to IMED. In August 1982, Warner-Lambert purchased all of the outstanding stock of IMED for approximately $163 per paired share of stock in IMED and International. Warner-Lambert paid a total of $465 million for all of the outstanding stock plus the extant stock options belonging to employees of IMED. Warner-Lambert, through IMED, issued Henry a 1982 Form W-2 that was filed as part of petitioners' 1982 Federal income tax return declaring $92,874.60 as income. Neither Warner-Lambert nor IMED provided Henry with another Form W-2 or 1099 or other form or statement that declared his stock option proceeds as income. Robert E. DouglasPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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