Wisconsin Central Ltd. v. U.S.

In action by railroad taxpayers seeking tax refund on ground that non-qualified stock options they provided to their employees were not taxable as “compensation” under Railroad Retirement Tax Act, Dist. Ct. did not err in finding that said stock options were subject to said tax. Fact that cash and stock options are not same thing did not make plaintiffs’ stock option plans any less form of monetary remuneration than cash, especially where employees can sell said options and have net proceeds deposited in employees’ bank accounts. (Dissent filed.)