SECTION 3. SCOPE

This revenue procedure applies only to the valuation for transfer tax purposes of nonpublicly traded compensatory stock options (that is, stock options that are granted in connection with the performance of services, including stock options that are subject to the provisions of § 421), on stock that, on the valuation date, is publicly traded on an established securities market. The options to which this revenue procedure applies are referred to herein as “Compensatory Stock Options.”