Burgess J.W. Raby & William L. Raby have published Unexpected Consequences of Stock Options and Restricted Stock, also available on the Tax Analysts web site as Doc 2005-23737, 2005 TNT 224-41. Here is the Introduction:
Four recent cases illustrate some of the tax traps awaiting employees (and independent contractors) who become instant millionaires when the companies for which they have worked go public and their options or restricted stock are suddenly in the money. After discussing those four, we will offer a few suggestions on the use of stock-related incentives in businesses that are not publicly traded.
- Hilen v. Commissioner, T.C. Memo. 2005-226
- Merlo v. Commissioner, T.C. Memo. 2005-178
- Speltz v. Commissioner, 124 T.C. No. 9 (2005)



