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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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