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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,
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