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HARRISON v. UNITED STATES

Civ. A. No. 78-1576.

475 F.Supp. 408 (1979)

Brian G. and Maureen HARRISON v. UNITED STATES of America.

United States District Court, E. D. Pennsylvania.

July 24, 1979.

Attorney(s) appearing for the Case

Paul S. Kimbol, Dechert Price & Rhoads, Philadelphia, Pa., for plaintiffs.

Gregory S. Hrebiniak, Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendant.

OPINION

LUONGO, District Judge.

Section 57(a)(6) of the Internal Revenue Code1 provides that with respect to stock transferred pursuant to the exercise of a qualified or a restricted stock option, "the amount by which the fair market value of the share at the time of exercise exceeds the option price" constitutes an item of tax preference subject to the minimum tax under § 56...

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