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Customarily, human beings would again feel the impulse to eat something not sooner than noon. Hence, we recommend that registration be required not sooner than the due date (including extensions) of the return for the year in which the taxpayer participates in the tax shelter. Employees holding stock options with exercise prices in excess of $10 per share, with certain exceptions, have the opportunity, if they so choose, to cancel those options in exchange for new options to be granted not sooner than June 11, 2003. |
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