Judith A. Madden - Page 4

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          Sturges exercised all of the Cisco stock options.  He sold some             
          of the Cisco stock acquired from the exercise of the stock                  
          options and retained the rest in a Paine Webber joint margin                
          account.  Petitioner and Mr. Sturges believed the retained Cisco            
          stock would be a conservative investment that would increase in             
          value.  At the time the options were exercised, Cisco stock was             
          selling for approximately $64 per share.                                    
               A portion of the proceeds from the sale of the Cisco stock             
          acquired from the exercise of the stock options was invested in             
          stock of biotechnology companies.  The biotechnology stock was              
          held in a separate Paine Webber joint account.                              
               The exercise of the Cisco stock options generated                      
          $1,596,461.44 of employment income to Mr. Sturges.  Petitioner              
          informed Paine Webber that she wanted to put aside sufficient               
          funds to pay the tax liability resulting from the exercise of the           
          Cisco stock options.                                                        
               Petitioner and Mr. Sturges withdrew $68,000 from their joint           
          Paine Webber account in September 2000.  They used the money for            
          home improvements and their daughter’s tuition.                             
               Cisco issued Mr. Sturges a Form W-2, Wage and Tax Statement,           
          for 2000 reporting wages of $1,683,886.77 that included Mr.                 
          Sturges’s income from his exercise of the stock options.  The               
          Form W-2 reported that $464,291.46 was withheld for Federal                 
          income taxes.                                                               






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