Paul A. Tanner, Sr. and Beverly N. Tanner - Page 12




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          Reports and Trading by Officers, Directors and Principal Security           
          Holders, 56 Fed. Reg. 7242, 7248 (Feb. 21, 1991).  Similar to how           
          an insider’s opportunity for profit begins when he purchases                
          stock, the opportunity for profit begins when an insider                    
          purchases or acquires an option because the insider knows at what           
          price he can obtain stock and can determine the extent of his               
          profit.7  Id.                                                               
               As a result, the amendments require that the acquisition of            
          the option, not its exercise, be deemed the significant event to            
          commence the 6-month restricted period under section 16(b).  Id.            
          The commentary explains that the exercise of an option merely               
          changes the form of beneficial ownership from indirect to direct,           
          representing “neither the acquisition nor the disposition of a              
          right affording the opportunity to profit”.  Id. at 7249.                   
               The parties dispute when the restricted 6-month period of              
          section 16(b) commences.  Respondent argues that, because of the            
          1991 amendments to the regulations for section 16(b), the 6-month           
          period begins at the date of the grant of the option.  Petitioner           
          concedes that if the 1991 amendment to the regulations for                  


               7  The rules explain that the amendments adopted do not                
          distinguish between options that are purchased and other options,           
          such as those granted in this case.  Final rules and solicitation           
          of comments:  Ownership Reports and Trading by Officers,                    
          Directors and Principal Security Holders, 56 Fed. Reg. at 7251.             
          Not to treat the employee option grant as a “purchase” for sec.             
          16(b) purposes would “provide a significant opportunity for the             
          short-swing transactions Congress wished to eliminate.”  Id.                






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