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PHILLIPPE v. COMMISSIONER

Docket No. 11296-80.

43 T.C.M. 343 (1982)

T.C. Memo. 1982-30

Edward J. Phillippe and Carolyn Phillippe v. Commissioner.

United States Tax Court.

Filed January 21, 1982.

Attorney(s) appearing for the Case

Harrison F. Comstock, Los Gatos, Calif., for the petitioners. Henry E. O'Neill, for the respondent.

Memorandum Opinion

FAY, Judge:

Respondent determined a deficiency of $39,114.00 in petitioners' Federal income tax for 1976.1 Due to concessions, the sole issue is to determine the fair market value of stock acquired by Edward J. Phillippe (petitioner) pursuant to the exercise of certain nonqualified stock options.

All the facts have been stipulated and are found accordingly.

Petitioners, Edward J. Phillippe and...

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