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Abstract

The treatment stock options have received since the enactment of Section 421 of the 1954 Code has come under much criticism. Section 421 of the Code authorizes the so-called "restricted"stock options. It is not the purpose of this paper, however, to enter the controversy about restricted stock options but to consider the so-called "non-restricted" and to suggest revisions in the law that appear merited with respect to them.

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