Elliot Pisem and David E. Kahen Vesting and Rescission: Estate of 'Kechijian v. Commissioner'
In their Taxation column, David E. Kahen and Elliot Pisem discuss Estate of Kechijian v. Commissioner, the third opinion addressing tax consequences of a 1998 acquisition of stock by Larry Austin and Arthur Kechijian.
August 19, 2020 at 10:42 AM
10 minute read
Estate of Kechijian v. Commissioner (962 F.3d 800 (4th Cir. 2020)) is the third opinion addressing tax consequences of a 1998 acquisition of stock by Larry Austin and Arthur Kechijian. The acquisition was made subject to a condition treated by the individuals as a "substantial risk of forfeiture" (SROF) within the meaning of Section 83 of the Internal Revenue Code. When the forfeiture condition later lapsed, each of the individuals tried to avoid recognition of substantial compensation income by surrendering shares and then immediately purchasing identical shares for a promissory note.
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