QSBS Related Tax Code Sections

QSBS Court Ruling: Owen v. Commissioner of Internal Revenue-Why is an “active business” requirement under (§1202(e)) important when applying a §1045?

United States Tax Court, Nos. 930–07, 1384–07, 13303–07, 29011–08, 29090–08, January 19, 2012 KEY QSBS TAKEAWAY(S): In Owen v. Commissioner, the taxpayer met the 60–day requirement of section 1045(a)(1) because the stock purchase agreement transaction was signed on June 17, 2002, and the sold Family First Companies shares--amounting to … Read More

QSBS Court Ruling: Natkunanathan v. Commissioner of Internal Revenue- Can acquired stock options during a merger and acquisition qualify for QSBS?

United States Tax Court, No. 17291–07, February 1, 2010 KEY QSBS TAKEAWAY(S): In Natkunanathan v. Commissioner, the taxpayer misused the definition under §1202(f) and argued stock options are equivalent to the sale or exchange of stock. Another key takeaway is the taxpayers failure to provide evidence that the … Read More