-35-
decline to sustain respondent’s determination that petitioners
are liable for an accuracy-related penalty for substantial
understatement of income tax. Accord Montgomery v. Commissioner,
127 T.C. 43, 67 (2002); Racine v. Commissioner, T.C. Memo. 2006-
162; Facq v. Commissioner, T.C. Memo. 2006-111.
E. Holdings
We hold that petitioner realized income in 2002 when she
exercised her stock options received from CTI. We also hold that
petitioners are not liable for the accuracy-related penalty
determined by respondent under section 6662(a) and (b)(2). We
have considered all arguments made by petitioners for a contrary
holding as to the deficiency, and we have considered all
arguments made by respondent for a contrary holding as to the
accuracy-related penalty. As to the arguments that we have
considered but not discussed herein, we have rejected those
arguments as without merit.
Decision will be entered
for respondent as to the
deficiency; decision will be
entered for petitioners as to
the accuracy-related penalty.
Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35
Last modified: November 10, 2007