Anthony J. Kadillak v. Commissioner

127 T.C. No. 13

UNITED STATES TAX COURT ANTHONY J. KADILLAK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2860-04L. Filed November 7, 2006. P, as a sales assistant with Ariba Technologies, Inc. (Ariba), received incentive stock options (ISOs) subject to an employment termination restriction, whereby Ariba had the right to repurchase nonvested stock on the date of termination for its exercise price. On Apr. 5, 2000, P exercised his ISOs and was transferred all vested stock. The nonvested stock was placed in escrow and transferred to P as the shares vested on a monthly…