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penalty under section 6662(a).1 We decide primarily whether
Susan Moore (petitioner) realized income in 2002 when she
exercised stock options received from her employer Cell
Therapeutics, Inc. (CTI). We hold she did. We also decide
whether petitioners are liable for the accuracy-related penalty
determined by respondent under section 6662(a). We hold they are
not.
FINDINGS OF FACT
Some facts were stipulated or contained in the exhibits
submitted therewith. We find the facts accordingly. Petitioners
are husband and wife, and they resided in Hansville, Washington,
when their petition was filed.
A. Petitioner’s Relationship With CTI Before January 13, 2001
CTI hired petitioner as a compensation consultant in January
1993, and she continued to work for CTI as a full-time employee
through January 12, 2001. Before working for CTI, petitioner had
earned a bachelor’s degree in business administration, and she
had worked for more than 10 years in various capacities (e.g.,
compensation manager, director of human resources) for various
other employers. Petitioner is certified by the American
Compensation Society as a professional in the field of
compensation.
1 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code.
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