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IRS Shuts Down Deferral of Income on Transfers of Stock Options to Related Persons

 By Philip J. Weis of Buchanan Ingersoll PC

The IRS has recently been taking a much more aggressive stand with respect to certain "tax shelters" and other tax motivated transactions which the IRS has viewed as abusive ro excessive. As part of this overall program, the IRS recently issued temporary and proposed Regulations under Section 83 of the Code, as well as Notice 2003-47.

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