IRWIN, Judge:
The respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1967 and 1968 in the amounts of $49,049 and $34,364, respectively. Various concessions having been made, the issues remaining for our decision are whether the nonstatutory stock option issued to Raymond B. Mitchell in 1966 by Royal Industries, Inc. (hereafter sometimes referred to as Royal), was granted in exchange for other stock options held by Mr...
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