Memorandum Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $8,497.00 in the petitioners' Federal income tax for 1972. The sole issue for decision is whether certain restrictions on the transferabliity of common stock received by an employee upon the exercise of a qualified stock option are to be considered in determining the fair market value of the stock for purposes of the minimum tax.
All of the facts were stipulated, and those...
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