Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency of $49,265.11 in petitioners' 1982 Federal income tax.
The issue for decision is whether petitioner James F. Etter 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 are to the Internal Revenue...
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