Jorge O. and Clelia E. Svoboda - Page 2

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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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