Respondent determined a deficiency of $286,659 in petitioners' 1994 Federal income tax. On their 1994 tax return, petitioners reported income from wages of $161,067.
The issues for decision are: (1) Whether petitioners had unreported income of $728,000 in 1994 from the exercise of a nonstatutory employee stock option; and (2) whether respondent proved a substantial omission of income under section...
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