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CH. 1—NORMAL TAXES AND SURTAXES
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the excess of the aggregate fair market value of all shares subject to the option immediately before such substitution or assumption over the aggregate option price of such shares, and (2) the new option or the assumption of the old option does not give the employee additional benefits which he did not have under the old option. For purposes of this subsection, the parent-subsidiary relationship shall be determined at the time of any such transaction under this subsection.
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§ 421(g)
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