STERRETT, Judge:
The Commissioner determined a deficiency in the petitioner's income tax for the calendar year 1960 in the amount of $644,187.86.
The issues presented for our decision are as follows:
(1) Whether the rules contained in section 1.421-6, Income Tax Regs., governing the taxation of nonstatutory stock options, are applicable to the instant case.
(2) Whether the options at issue had a readily ascertainable fair market value...
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