Hartman v. United States

OPINION AND ORDER

SWEENEY, Judge.

As a result of Ernst & Young LLP’s sale of its consulting services business in 2000, William F. Hartman received stock in Cap Gemini, S.A. He and his wife, Therese Hartman, reported the receipt of that stock as income on their 2000 federal income tax return and paid the resulting tax. They now seek a partial refund of the tax they paid, alleging that Mr. Hartman did not receive all of the stock in 2000. The parties’ cross-motions for summary judgment are presently before the court. For the reasons set forth below, the court concludes that the Hartmans are not…