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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