United States Fourth Circuit
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
- Published 2017/01/06
Judges
- KEENAN
Court
- United States Fourth Circuit