Riverton Investment Corp. v. United States

MEMORANDUM OPINION

MICHAEL, Senior District Judge.

This is a tax refund case. The plaintiff alleges that payments it made to its employees to buy back previously-issued stock were not non-deductible payments made to redeem stock, but deductible payments for compensation. On cross-motions for summary judgment, the presiding United States Magistrate Judge recommended that the court enter judgment in favor of the United States. The plaintiff filed timely objections. 1

Although buying back previously-issued stock intuitively appears to be a “redemption” of stock, a closer examination of the matter…