Research Problem 5. Before Lemon Corporation engaged in a B reorganization with Green Corporation, some of the employees of Lemon had unexercised options to purchase stock of Lemon. Under an employee agreement, Lemon canceled the unexercised stock options by paying the employees the difference between the option price and the current fair market value of Lemon’s stock. These employees reported this as ordinary income.
Can Lemon corporation deduct these payments to the employees, or are the stock option termination payments treated as capital expenditures?