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VENTURE FUNDING, LTD. v. COMMISSIONER

Docket No. 4174-95.

110 T.C. 236 (1998)

VENTURE FUNDING, LTD., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 26, 1998.

Attorney(s) appearing for the Case

Joseph Falcone, Brian H. Rolfe, and Robert J. Zinkel, Jr., for petitioner.

Mark I. Siegel, for respondent.

OPINION

LARO, Judge:

This case was submitted to the Court fully stipulated. See Rule 122. Petitioner petitioned the Court to redetermine respondent's determination of deficiencies of $347,583 and $27,578 in its 1988 and 1989 Federal income taxes. We must decide whether section 83(h) prevents petitioner from currently deducting the value of stock that it transferred to its employees in 1988 as compensation for services. We hold it does.

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