Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency of $3,975 in petitioners' Federal income tax for 1976. The sole issue for decision is the fair market value of stock acquired by petitioner Robert N. Hinton, Jr., pursuant to his exercise of a qualified stock option.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
Robert N. Hinton, Jr. (hereinafter petitioner...
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