United States Federal Circuit

Under section 83(h) of the Internal Revenue Code, addressesing deductions for employers who use property transfers (other than money) to compensate employees, the amount of the employer's deduction is the value of the transferred property that is includible in the employee's gross income as a matter of law as opposed to only the amount that is actually included in the employee's gross income.

Appellate Information

• Decided 07/15/2003
• Published 07/15/2003

Judges

• BRYSON, Circuit Judge., Before RADER, Circuit Judge, PLAGER, Senior Circuit Judge, and BRYSON, Circuit Judge.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Robert L. Moore, II,Miller & Chevalier, Chartered, of Washington, DC, argued for plaintiffs-appellants.   With him on the brief were Samuel M. Maruca and Alan I. Horowitz.


• For Appellees:
  
• Charles Bricken, Attorney, Tax Division, Department of Justice, of Washington, DC, argued for defendant-appellee.   With him on the brief was Richard Farber, Attorney.