-2- deficiency in their 2000 Federal income tax and an addition to tax of $5,197.70 under section 6651(a). After concessions by respondent, we are left to decide the date on which to value stock transferred to Edward Walter (petitioner) through his exercise of stock options. Respondent argues that the appropriate valuation date is July 14, 2000. Petitioners argue that the appropriate valuation date is July 18, 2000. We agree with respondent. Background All facts were stipulated or contained in the exhibits submitted therewith. We find the facts accordingly. At the time of the filing of the petition herein, petitioners resided on Bainbridge Island, Washington. Stock Option Grants Petitioner was employed by Primus Knowledge Solutions Inc. (Primus), until his employment terminated on May 5, 2000. As an employee of Primus, petitioner was granted three separate options to purchase its publicly traded common stock. More specifically, respective stock option letter agreements dated February 4, 1999, granted petitioner a nonqualified stock option (first option) to purchase 78,182 shares of Primus stock, a nonqualified stock option (second option) to purchase 16,666 shares of Primus stock, and an incentive stock option (third option) to purchase 48,484 shares of Primus stock. The exercise price under each of thesePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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