This
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article from The Tax Adviser,
published by
American Institute of CPA's on April 1, 1994. The length of the
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From the supplier: A corporate taxpayer that was denied deductions for dividends and stock paid to corporate officers because of failure to withhold income taxes for the transfers will be taking the issue to the Tax Court. Statutory authority for the withholding requirement appears to be in doubt, and the IRS has often chosen not to enforce it. The transfer was included in income when substantial risk of forfeiture ended, and deductions were taken in the same year, consistent with Internal Revenue Code section 83. The dividends involved may not even be subject to section 83 treatment.
Citation DetailsTitle: Disallowance of deduction for failure of employer to withhold on stock disputed.
Author: Bill Dunn
Publication:The Tax Adviser (Magazine/Journal)
Date: April 1, 1994
Publisher: American Institute of CPA's
Volume: 25
Issue: n4
Page: 216(2)
Distributed by Thomson Gale.
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