Legal Opinion

Venture Funding v. Commissioner

United States Tax Court

Decided March 26, 1998No. Tax Ct. Dkt. No. 4174-95Published

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.

1Opinion of the Court

VENTURE FUNDING, LTD., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Venture Funding v. Commissioner

Tax Ct. Dkt. No. 4174-95

United States Tax Court

110 T.C. 236; 1998 U.S. Tax Ct. LEXIS 19; 110 T.C. No. 19;

March 26, 1998, Filed

Decision will be entered for respondent.

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…

Also in this document: Concurrence; Concurring in part, dissenting in part; Dissent · Ruwe; Dissent · Halpern.

2Cases cited40 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Welch v. HelveringSupreme Court of the United States · 1933
  3. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  4. Connecticut National Bank v. GermainSupreme Court of the United States · 1992
  5. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934

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