David R. Fuller appeared at the Treasury regulation hearing on the payroll tax treatment of statutory stock options. The May 14 issue of Tax Notes Today, published an article in advance of that hearing in which Mr. Fuller was quoted extensively. "The IRS guidance has a broad and chilling effect on statutory stock options," observed Mr. Fuller, who has written on the subject, and was involved in the related Sun Microsystems litigation while at the IRS. Mr. Fuller has strenuously defended employer and employee rights to rely on the IRS' longstanding favorable treatment of the plans. Mr. Fuller also commented that there is a "significant administrative burden of tracking, withholding, depositing, and reporting on the exercises" and that the guidance "clearly does not go far enough to alleviating that burden."