- 2 -
tion). Neither party has requested a hearing, and we conclude
that a hearing is not necessary. Rule 232(a)(2). Based on the
submissions of the parties, we shall deny petitioners’ motion.
Background
The record establishes and/or the parties do not dispute the
following.2
During 2002, petitioner Young J. Kim (Ms. Kim) was employed
by Fannie Mae. At a time not disclosed by the record before
January 17, 2002, Fannie Mae granted Ms. Kim certain options
(Fannie Mae options) to buy Fannie Mae stock under an employee
stock purchase plan (Fannie Mae ESPP).
Pursuant to the Fannie Mae ESPP, on four dates in January
2002, Ms. Kim exercised certain Fannie Mae options and acquired
certain shares of Fannie Mae stock. In order to have the money
to pay the exercise price of the options exercised, on the dates
on which she exercised such options, Ms. Kim sold for certain
gross proceeds certain shares of Fannie Mae stock acquired as a
result of the exercise of such options.
Fannie Mae issued to Ms. Kim Form W-2, Wage and Tax State-
ment (Fannie Mae Form W-2), for her taxable year 2002. That form
showed total wages, tips, and other compensation of $95,323.62.
2We incorporate herein by reference the Court’s Memorandum
Findings of Fact and Opinion in Kim v. Commissioner, T.C. Memo.
2007-14 (Court’s Opinion), and set forth the portions of that
Opinion that are relevant to our disposition of petitioners’
motion.
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