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MONTELEPRE SYSTEMED, INC. v. C.I.R.

No. 91-4395.

956 F.2d 496 (1992)

MONTELEPRE SYSTEMED, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied May 6, 1992.

Attorney(s) appearing for the Case

Sullivan & Stolier, Daniel J. Daigle, Jack M. Stolier, New Orleans, La., for petitioner-appellant.

Abraham N.M. Shashy, Jr., Chief Counsel, IRS, Shirley D. Peterson, Asst. Atty. Gen., Tax Div., Gary R. Allen, Chief, Dept. of Justice, Robert W. Metzler, Jonathan S. Cohen, Kenneth W. Rosenberg, Washington, D.C., for respondent-appellee.

Before REAVLEY, HIGGINBOTHAM and DEMOSS, Circuit Judges.

REAVLEY, Circuit Judge:

Taxpayer Montelepre Systemed, Inc. (Systemed) gave up one of its rights under a management contract in exchange for money. The Tax Court characterized the payment that Systemed received as compensation taxable under 26 U.S.C. § 83 in the first year that Systemed's right ceased being subject to a substantial risk of forfeiture. We hold that Systemed's right was subject to a substantial risk of forfeiture until Systemed disposed of that...

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