United States Fourth Circuit

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QinetiQ US Holdings, Inc. v. Commissioner of IRS, 15-2192

In a case involving the federal income tax treatment of shares of stock issued to an executive employee, the Tax Court's judgment in favor of the IRS is affirmed where: 1) the IRS complied with all applicable procedural requirements in issuing the Notice of Deficiency; and 2) the tax court did not err in concluding that the stock failed to qualify as a deductible expense for the tax year ending March 31, 2009, because the stock was not issued subject to a substantial risk of forfeiture.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2017/01/06




  • United States Fourth Circuit


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