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WALTER v. COMMISSIONER

Dkt. No. 12106-05.

93 T.C.M. 1228 (2007)

T.C. Memo. 2007-123

Walter and Susan Moore v. Commissioner.

United States Tax Court.

May 17, 2007.

Attorney(s) appearing for the Case

Brian Isaacson and Duncan Turner (specially recognized), for petitioners.

Kirk M. Paxson and Julie Payne, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Petitioners petitioned the Court to redetermine respondent's determination of a $810,805 deficiency in their 2002 Federal income tax and a $162,161 accuracy-related penalty under section 6662(a).1 We decide primarily whether Susan Moore (petitioner) realized income in 2002 when she exercised stock options received from her employer Cell Therapeutics, Inc. (CTI). We hold she...

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