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Text of Notice 2004-28: IRS Identifies Frivolous Arguments About Compensatory Stock Options (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] Mar. 26, 2004
7 pages. Excerpt: The Internal Revenue Service is aware that certain promoters are advising taxpayers to take highly questionable, and in most cases meritless, positions, described below, on current and amended returns regarding income or alternative minimum tax ('AMT') due upon the exercise of nonstatutory or statutory stock options. This Notice alerts taxpayers that the Service intends to challenge such positions and will treat them as frivolous in appropriate cases.
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