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MONTGOMERY v. COMMISSIONER

Docket No. 633-05.

127 T.C. 43 (2006)

127 T.C. No. 3

NIELD AND LINDA MONTGOMERY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 28, 2006.

Attorney(s) appearing for the Case

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

Kirk M. Paxson, Julie L. Payne, and William C. Schmidt, for respondent.

HAINES, Judge:

Respondent determined a deficiency of $417,601 in petitioners' Federal income tax for 2000 and an accuracy-related penalty of $83,520 under section 6662(b).1 All references to petitioner in the singular are to petitioner Nield Montgomery.

After concessions,2 the issues remaining for decision are:

(1) Whether petitioner's rights in shares of stock acquired upon the exercise...

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