- 4 - marketing. As part of his compensation package, petitioner received a monthly salary of $10,000 and a $300,000 yearly bonus if his target goals were reached. Petitioner was also granted several stock options pursuant to i2’s Stock Option Agreement (Agreement), which consisted of ISOs and nonstatutory stock options (NSOs). To the extent relevant to this case, these options are set forth in the table below: Option grant ISO or NSO as of Number of Exercise date date of option shares granted price per grant share 12/29/95 ISO 276,000 $0.1475 12/15/97 ISO 78,272 5.10938 12/15/97 NSO 1,728 5.10938 10/21/98 ISO 28,696 3.48438 10/21/98 NSO 91,304 3.48438 The Agreement provided, among other things, that ISOs would cease to qualify for favorable tax treatment if (and to the extent) they were exercised more than 3 months after the date the employee/optionee ceased to be an employee of i2 for any reason other than death or permanent disability. The Incentive Stock Option Agreement (ISO Agreement), accompanying the Agreement, stated that if the ISOs did not qualify as an incentive stock option, there might be a regular Federal income tax liability upon the exercise of the option.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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