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"Disqualifying" Dispositions of Option Stock
July 29, 2015
On September 17, 1964, Mr. B was granted an option to purchase 3,000 shares of P Corporation, (P), stock at 9 7/8 per share pursuant to P's qualified stock option...

"Robert Willens LLC is neither a registered investment advisor nor a broker/dealer. Subscribers and/or readers are advised that the information contained in The Willens Report is not to be construed or relied upon as investment, tax planning, accounting and/or legal advice, nor is it to be construed in any way as a recommendation to buy, hold or sell (short or otherwise) any security or any other form of investment. All opinions, analyses and information contained herein is based upon sources believed to be reliable and is written in good faith, but no representation or warranty of any kind, express or implied, is made herein concerning any investment, tax, accounting and/or legal matter or the accuracy, completeness, correctness, timeliness and/or appropriateness of any of the information contained herein. Subscribers and/or readers are further advised that the Company does not necessarily update the information and/or opinions set forth in this and/or any subsequent edition of The Willens Report or any version thereof. Readers are urged to consult with their own independent professional advisors with respect to any matter analyzed herein. All information contained herein and/or this website should be independently verified."


Recent Reports

Stock Is Not "Debt Financed Portfolio Stock"
July 28, 2015
X Corporation, (X), is the parent of a consolidated group of corporations engaged in financial service activities. X is publicly held. &nb...
Two More Tax-Free Reorganizations
July 27, 2015
The pace of mergers has not shown any sign of slowing down, even during the normally slow summer months. Over the last few days, two transformative business combinations were i...
Proposed Regulations Treat Allocations As Payments For Services
July 27, 2015
Generally, an allocation or distribution between a partnership and a partner for the provision of services can be treated as: (i) a distributive share, (ii) a guaranteed paymen...
Interest-Free Loan is "Held for Investment"
July 27, 2015
As of January 1, 1988, the taxpayer, TP, had made interest-free demand loans to Foundation, F, with a total unpaid balance of $352x. During 1988, F repaid TP $121x, t...