Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency of $89,289.14 in petitioners' 1982 Federal income tax.
After concessions, the issue remaining for decision is whether petitioner Dennis R. Haydon was granted an incentive stock option, taxation of which is governed by sections 421 and 422A, or a nonqualified stock option, taxation of which is governed by section 83. Unless otherwise indicated, all section references...
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