-2- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007