Qinetiq US Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue

Affirmed by published opinion. Judge KEENAN wrote the opinion, in which Judge KING and Judge DIAZ joined.

BARBARA MILANO KEENAN, Circuit Judge:

This appeal from a decision of the United States Tax Court (the tax court) involves the federal income tax treatment of shares of stock issued to an executive employee of Dominion Technology Resources, Inc. (DTRI), around the time of DTRI’s founding. The company’s successor in interest, QinetiQ U.S. Holdings, Inc. & Subsidiaries (QinetiQ), contends that the stock was issued in connection with the executive’s employment and was subject to a substantial…