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of InsWeb common stock subject to a substantial risk of
forfeiture. Petitioner’s shares of stock were not forfeited but
were sold to pay Comerica when he filed for bankruptcy.
In consequence of the foregoing, we hold petitioner received
gross income from the exercise of his nonstatutory stock options
in 1999.
In reaching our holdings herein, we have considered all
arguments made, and to the extent not mentioned above, we
conclude that they are moot, irrelevant, or without merit.
To reflect the foregoing,
An appropriate order
and decision will be entered.
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