- 10 - for a continuance and remand. On December 8, 2004, the Court retained jurisdiction and remanded this case to respondent’s Appeals Office for another administrative hearing to consider petitioner’s underlying tax liability for the years at issue. On March 2, 2005, Appeals Officer Mountjoy held an administrative hearing with Mr. Isaacson during which he argued that: (1) The stock at issue was not transferred to petitioner because it was pledged to a lender as security for nonrecourse debt;5 and (2) petitioner continued his employment with i2 after his resignation and termination on December 31, 1999, until October 2000, and as a result, the exercise of the options qualified for nonrecognition of income pursuant to section 421. During the conference, Mr. Isaacson said he would provide additional documents to support petitioner’s claim that he continued his employment with i2 after December 31, 1999, and provide a declaration from petitioner’s former boss, Greg Brady, which would indicate that Mr. Brady accepted petitioner’s resignation in December 1999 and petitioner continued on as an employee with i2 after January 2000. On April 19, 2005, Appeals Officer Mountjoy mailed a letter to Mr. Isaacson requesting him to submit the documentation and declaration supporting petitioner’s claim. On August 1, 2005, 5 This issue has been conceded. See supra note 2.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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