Venture Funding, Ltd. - Page 14

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          12, and its effect that an employer's deduction is in fact offset           
          by a corresponding inclusion in income comports with the                    
          statute's purpose of matching an employer's deduction with income           
          inclusion by the employee.                                                  
               The history of these regulations is noteworthy.  When the              
          Commissioner originally proposed these regulations in 1971, they            
          did not contain a safe harbor provision under which an employer             
          could deduct the value of property transferred to an employee as            
          compensation for services, absent the employee's including the              
          corresponding amount in income.  Section 1.83-6, Income Tax                 
          Regs., was originally proposed as follows:                                  
                    �1.83-6.  Deduction by employer.--(a) In general.                 
               In the case of a transfer of property in connection                    
               with the performance of services * * *, there is                       
               allowed as a deduction under section 162 or 212, to the                
               person for whom such services were performed, an amount                
               equal to the amount included, under subsection (a) * *                 
               * of section 83 as compensation, in the gross income of                
               the person who performed such services, but only to the                
               extent such amount meets the requirements of section                   
               162 or 212 and the regulations thereunder.  Such                       
               deduction shall be allowed only for the taxable year of                
               such person in which or with which ends the taxable                    
               year for which such amount is included as compensation                 
               in the gross income of the person who performed such                   
               services. * * *  [Sec. 1.83-6, Proposed Income Tax                     
               Regs., 36 Fed. Reg. 10793 (June 3, 1971).]                             
          After these proposed regulations were published, the Commissioner           
          received numerous comments expressing concern as to the                     
          difficulty that an employer may have in demonstrating that an               
          amount has actually been included in an employee's gross income.            
          Accordingly, the Commissioner, in finalizing the proposed                   





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