Kimberlin v. Commissioner (filed 5/8/07 - Warrants)

In this Tax Court case, the IRS argued that warrants were taxable in the year of exercise, while the taxpayers argued that the warrants had a readily ascertainable value in 1995 and were taxable in that year. The Court determined that the IRS’ expert was not credible. “Once the Court qualified him as an expert, the performance of respondent’s expert, a former ski instructor, went downhill fast.” On the other hand, “Petitioners’ expert, founder of an economic consulting company, was credible, consistent, and highly qualified.”


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