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HILEN v. COMMISSIONER

Docket No. 21768-03.

90 T.C.M. 333 (2005)

T.C. Memo. 2005-226

Keith D. Hilen v. Commissioner.

United States Tax Court.

September 29, 2005.

Attorney(s) appearing for the Case

Brian G. Isaacson and Duncan C. Turner, for petitioner.

Sandra Veliz, for respondent.

MEMORANDUM OPINION

HAINES, Judge:

This case is before the Court on the parties' cross-motions for summary judgment pursuant to Rule 121.1 The issue for decision is whether petitioner received gross income from the exercise of nonstatutory stock options in 1999.

Background

At the time of the filing of the petition in this case, petitioner resided in Santa Rosa, California.

In May 1995, petitioner...

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