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ROBERT C. v. COMMISSIONER

Docket No. 17633-04.

92 T.C.M. 100 (2006)

T.C. Memo. 2006-162

Robert C. and Gail K. Racine v. Commissioner.

United States Tax Court.

August 14, 2006.

Attorney(s) appearing for the Case

Don Paul Badgley and Brian Gary Isaacson, for petitioners.

Kirk M. Paxson and William C. Schmidt, for respondent.

MEMORANDUM OPINION

GOEKE, Judge:

Respondent determined a $514,462 deficiency in petitioners' Federal income tax and determined that petitioners are liable for a $102,892.40 accuracy-related penalty under section 6662(a)1 for 2000. We are asked to decide whether petitioners received income in 2000 when petitioner Gail Racine (Mrs. Racine) exercised her nonstatutory stock options...

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