United States Ninth Circuit

In a tax dispute involving when a taxpayer can postpone calculation of nonstatutory stock options as income attributable to her option exercises, 26 U.S.C. sections 83(a) and (e)(3)-(e)(4); 26 C.F.R. section 1.83-7(a), judgment of the trial court is reversed where the taxpayer has not demonstrated an entitlement to deferral of tax consequences under Internal Revenue Code section 83(c)(3).

Appellate Information

• Decided 04/06/2011
• Published 04/06/2011

Judges

• BERZON

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Darrell D. Hallett, Kenneth L. Greene