Claims Court Rules IRC Section 409A Governs Discounted Stock Option

Business Valuation UpdateVol. 19 No. 6
Legal and Court Case Update
June 2013
3674 Semiconductors and Related Devices
334413 Semiconductor and Related Device Manufacturing
federal taxation

Sutardja v. United States
2012 U.S. Claims LEXIS 126
February 27, 2013
US
Federal Court
Federal
United States Court of Federal Claims
N/A
Wheeler

Summary

Claims court disagrees with taxpayers claiming that issue of whether an option to buy stock in company was discounted was not relevant to finding no taxpayer liability under IRC section 409A; if the option was discounted¬—a factual issue awaiting determin ...

See Also

Sutardja v. United States

Claims court disagrees with taxpayers claiming that issue of whether an option to buy stock in company was discounted was not relevant to finding no taxpayer liability under IRC section 409A; if the option was discounted¬—a factual issue awaiting determin ...