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respect to petitioners' 2002 taxable year. After concessions,2
the issues for decision are: (1) Whether petitioner Jorge O.
Svoboda received compensation income of $73,374 from his employer
Fluor Corporation (Fluor) upon his exercise of stock options, and
sale of the acquired stock, during the taxable year; and (2)
whether petitioners are liable for an accuracy-related penalty
under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petition, petitioners Jorge O. Svoboda (petitioner) and
Clelia E. Svoboda (Mrs. Svoboda) resided in San Clemente,
California.
Petitioner was born in Chile in 1941 and emigrated to the
United States more than 40 years ago. After moving to the United
States, petitioner earned a master's degree in business
2 Petitioners have conceded that they are not entitled to
any deduction for contributions to an individual retirement
account and that they failed to report taxable dividends of
$6.00. Respondent has conceded that petitioners did not have
unreported income with respect to a State income tax refund.
Petitioners have also conceded that, in the event respondent's
determinations in the notice of deficiency are sustained (except
with respect to the State income tax refund), petitioners are
liable for an increased deficiency and increased addition to tax
when their liability for the alternative minimum tax is taken
into account.
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