- 17 -
percent of the amount of gross income stated on the return. See
sec. 6501(e)(1)(A).
Petitioner reported gross income of $161,067 on his joint
return for the 1994 tax year. In accord with our holding that
petitioner did not report $728,000 from the exercise of his stock
option, petitioner’s omitted gross income exceeded 25 percent of
the gross income reported on the return, and the 6-year
assessment period is applicable. We conclude that the assessment
period had not expired at the time respondent mailed the notice
of deficiency for petitioner’s 1994 taxable year.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not herein
discussed, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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