Herman E. and Sheri L. Villarroel - Page 3

                                        - 3 -                                         
          stock called Series C ESOP Convertible Preferred Stock (ESOP                
          stock).  Petitioner's account balance vested when she completed 5           
          years of service.                                                           
               Petitioner decided to terminate her employment with Oral B             
          in October 1994.  On a distribution request form dated October              
          27, 1994, petitioner elected to receive payment of her entire               
          account balance in the form of Gillette common stock plus the               
          cash value of any fractional shares of such stock.  As of                   
          September 30, 1994, the account had 15.1473 shares of ESOP stock            
          which were convertible into 302.946 shares of Gillette common               
          stock.                                                                      
               On or about December 12, 1994, the plan distributed to                 
          petitioner 302 shares of Gillette common stock with a fair market           
          value of $73.19 per share at the time of distribution for a total           
          fair market value of $22,105.71.  The distribution also included            
          cash in the amount of $217.39, representing the cash value of her           
          fractional share of Gillette common stock plus the cash value of            
          the dividends accumulated in her account between October 1, 1994,           
          and the date of the distribution.  Petitioner did not receive the           
          cash because an equal amount was withheld for Federal income tax            
          purposes.2                                                                  
               Petitioner sold a number of shares of Gillette common stock            
          for $6,114.79 on December 20, 1994.  On their 1994 return,                  

          2         Respondent allowed petitioners a withholding credit in            
          the amount of $217 in the statutory notice of deficiency.                   




Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011