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JOHNSON v. COMMISSIONER

Docket No. 10058-76.

74 T.C. 89 (1980)

GEORGE E. JOHNSON AND SYLVIA V. JOHNSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 22, 1980.

Attorney(s) appearing for the Case

Jack A. Cozy and Earl C. Crouter, for the petitioners.

John O. Kent, for the respondent.

SIMPSON, Judge:

The Commissioner determined a deficiency of $199,578 in the petitioners' Federal income tax for 1971 and an addition to the tax of $9,979 under section 6653(a), I.R.C. 1954.1 The parties have settled certain issues, and the issues remaining for decision are: (1) Whether for purposes of determining the income from the exercise of employee stock options, the fair market value of the stock so acquired is to be based...

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