Pursuant to a written plan, Smith Corp. paid all its employees 100 stock options on January 1, 20X1. The stock is not readily tradeable on an established market. Phil, who is an employee but not an officer or shareholder, immediately exercised all his 100 options
- on January 1, 20X1 at an exercise price of $10. The FMV of each stock is $50
- on January 1, 20X1, and rises to $70 on January 1, 20X3, and then reaches $100
- on January 1, 20X6 before dropping to $80
- on January 1, 20X7. Assuming Phil made a timely Sec. 83(i) election and Phil is promoted to CFO on January 1, 20X7

a. when does Phil have income and how much?