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QINETIQ US HOLDINGS, INC. & SUBSIDIARIES v. C.I.R.

No. 15-2192.

845 F.3d 555 (2017)

QINETIQ US HOLDINGS, INC. & SUBSIDIARIES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided: January 6, 2017.

Attorney(s) appearing for the Case

ARGUED: Gregory G. Garre , Latham & Watkins LLP, Washington, D.C., for Appellant. Ellen Page DelSole , United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Gerald A. Kafka , Benjamin W. Snyder , Nicolle Nonken Gibbs , Latham & Watkins LLP, Washington, D.C., for Appellant. Caroline D. Ciraolo , Acting Assistant Attorney General, Diana L. Erbsen , Deputy Assistant Attorney General, Gilbert S. Rothenberg , Teresa E. McLaughlin , Tax Division, United States Department of Justice, Washington, D.C., for Appellee.

Affirmed by published opinion. Judge Keenan wrote the opinion, in which Judge King and Judge Diaz joined.

This appeal from a decision of the United States Tax Court (the tax court) involves the federal income tax treatment of shares of stock issued to an executive employee of Dominion Technology Resources, Inc. (DTRI), around the time of DTRI's founding. The company's successor in interest, QinetiQ U.S. Holdings...

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