Allen v. Connecticut Commissioner of Revenue Services

Issue: Whether the Connecticut Supreme Court violated the principles expressed in Helvering v. Horst and Oklahoma Tax Commission v. Chickasaw Nation and widened a conflict among lower courts when it held that Connecticut may tax income from a nonresident's exercise of stock options because he supposedly realized that income when he received the options as compensation for work in Connecticut and not when, as a nonresident, he exercised the options.