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ROBINSON v. U.S.

No. 02-5154.

335 F.3d 1365 (2003)

James G. ROBINSON and Barbara L. Robinson, Plaintiffs-Appellants, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

DECIDED: July 15, 2003.

Attorney(s) appearing for the Case

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.

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

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

BRYSON, Circuit Judge.

This appeal from the United States Court of Federal Claims requires us to construe section 83(h) of the Internal Revenue Code, a provision that addresses deductions for employers who use property transfers (other than money) to compensate employees. That statute provides that the amount of the employer's deduction is "equal to the amount included" in the employee's gross income as a result of the transfer...

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