This article analyzes the judicial interpretations of "amount realized" to a shareholder upon transfer of stock to a corporate employee. The author criticizes the overextension of the Davis presumption - when properties are exchanged at arms length their values are approximately equal - to the stock transfer situation. He concludes that a more appropriate test would be to examine the nature of the property received to determine whether the Davis presumption should be applied.
Belan K. Wagner,
Taxation of Stock Transfers Between Corporate Shareholders and Employees,
31 U. Miami L. Rev.
Available at: http://repository.law.miami.edu/umlr/vol31/iss1/4