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admissible, but that such questions cannot be decided in the
context of this summary judgment motion. Likewise, petitioner’s
proposed evidence of the nonexistence of such an arm’s-length
sharing of stock option costs is not being “judged” at this time.
To reflect the foregoing,
An order will be issued
denying petitioner’s motion for
partial summary judgment regarding
the “section 482 stock-option cost-
sharing issue”.
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Last modified: May 25, 2011