- 2 - Held: R’s determination is in error because the warrants were not transferred in connection with the performance of services. Held, further, the warrants had an ascertainable fair market value on the date of grant in 1995 and are therefore taxable in that year. Solomon Leo Warhaftig, David Lederkramer (specially recognized), Peter Adebanjo (specially recognized), and Andre Castaybert (specially recognized), for petitioners. Lydia Branch, Shawna Early, and Fredrick Mutter, for respondent. OPINION FOLEY, Judge: The issues for decision in these cases are whether: (1) Warrants issued to petitioners in accordance with a settlement and release agreement were transferred in connection with the performance of services and therefore constitute taxable income pursuant to section 83;2 (2) the warrants had a readily ascertainable fair market value in 1995, on the date of grant, or in 1997, the year of exercise; and (3) the payment to Kevin 2 Unless otherwise indicated, all section references are to the Internal Revenue Code for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007