Venture Funding, Ltd. - Page 1

                                   110 T.C. No. 19                                    


                               UNITED STATES TAX COURT                                


                        VENTURE FUNDING, LTD., Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4174-95.           Filed March 26, 1998.                    

                    P transferred stock to its employees as                           
               compensation for services, and it claimed a deduction                  
               in the year of transfer for the value of the stock.                    
               None of P's employees included the value of the                        
               transferred stock in his or her gross income for the                   
               year of transfer.                                                      
                    Held:  Sec. 83(h), I.R.C., does not allow P to                    
               deduct the reported amount in the year of transfer.                    


               Joseph Falcone, Brian H. Rolfe, and Robert J. Zinkel, Jr.,             
          for petitioner.                                                             
               Mark I. Siegel, for respondent.                                        








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