Walter and Susan Moore - Page 2




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          penalty under section 6662(a).1  We decide primarily whether                
          Susan Moore (petitioner) realized income in 2002 when she                   
          exercised stock options received from her employer Cell                     
          Therapeutics, Inc. (CTI).  We hold she did.  We also decide                 
          whether petitioners are liable for the accuracy-related penalty             
          determined by respondent under section 6662(a).  We hold they are           
          not.                                                                        
                                  FINDINGS OF FACT                                    
               Some facts were stipulated or contained in the exhibits                
          submitted therewith.  We find the facts accordingly.  Petitioners           
          are husband and wife, and they resided in Hansville, Washington,            
          when their petition was filed.                                              
          A.  Petitioner’s Relationship With CTI Before January 13, 2001              
               CTI hired petitioner as a compensation consultant in January           
          1993, and she continued to work for CTI as a full-time employee             
          through January 12, 2001.  Before working for CTI, petitioner had           
          earned a bachelor’s degree in business administration, and she              
          had worked for more than 10 years in various capacities (e.g.,              
          compensation manager, director of human resources) for various              
          other employers.  Petitioner is certified by the American                   
          Compensation Society as a professional in the field of                      
          compensation.                                                               



               1 Unless otherwise indicated, section references are to the            
          applicable versions of the Internal Revenue Code.                           





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