Bulletin No. 2005-22 May 31, 2005

ilar to those described in Notice 2003–47. The transaction generally involved executives transferring compensatory stock options or restricted stock to a related person in exchange for a long-term, unsecured deferred payment obligation. It addresses (1) the penalty under the initiative for taxpayers with unexercised options or nonvested stock, (2) the application of section 6654 for a settlement of taxable year 2004, and (3) filing disclosure statements under regulations section 1.6011–4 for taxpayers that settle their transactions under the initiative. Taxpayers have until May 23, 2005, to notify the Service of their intent to participate in the settlement initiative.