-3- this opinion, references to petitioner are references to Mr. Ramzy M. Kopty. From March 18, 1991, through the end of 1997, petitioner was employed by a software company, J.D. Edwards & Co. On or about July 1, 1992, he began participating in the J.D. Edwards Employee Stock Ownership Plan (ESOP), a qualified plan under which the company made contributions of its stock to petitioner’s account in the plan. By December 31, 1997, when petitioner left the employ of J.D. Edwards & Co., the company had contributed 10,323.9064 shares of its stock into petitioner’s ESOP account. Set out below are the number of shares of J.D. Edwards & Co. stock, the aggregate value of those shares of stock, the cash held in petitioner’s ESOP account, and the total value of petitioner’s account, at the end of each of the years 1992 through and including 1997: Year Shares Value Cash Total 1992 20.3100 $3,756.70 ($57.43) $3,699.27 1993 36.1085 6,818.47 1,608.94 8,427.41 1994 66.0084 15,698.12 1,725.72 17,423.84 1995 108.1071 46,776.86 6.29 46,783.15 1996 144.5164 108,732.69 30.90 108,763.59 1996 110,116.1480 1997 10,323.9064 304,555.24 10.31 304,565.55 1Number of shares restated to reflect a 70-to-1 stock split. After petitioner left J.D. Edwards & Co. at the end of 1997, he began working through a sole proprietorship, Kopty Management Consulting. In that capacity, he provided management,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008