More on Robinson v. U.S. . .

RIA has published this article discussing Robinson v. U.S., a decision from the United States Court of Appeals for the Federal Circuit which ruled on certain aspects of Internal Revenue Code section 83. The decision was discussed in great detail in a separate post here and also by Stuart Levine in his Tax and Business Law Commentary here. The RIA article states that the IRS has recently mounted a multi-pronged attack against employees who attempt to defer income recognition by transferring nonstatutory compensatory stock options to related parties for long-term notes. The article goes on to say that for “companies with employees who used this type of scheme, the Federal Circuit’s decision may make it possible for the companies to gain deductions before the final tax treatment to the employees is ultimately resolved by a court or by agreement with IRS.”