Edward L. Walter and Jamie K. Walter - Page 2

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          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 these             






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