$37.$ Taxpayer T $("$T$\text{'})$ worked for company C $("$C$").$ C paid T a yearly salary of $$100,000$ plus a bonus. On December

$29,2020,$ C paid Ta bonus that consisted of $100$ shares of C company stock which had a fair market value $("$FMV$")$ of $$1,000$ per share. T was required to work for $2$ years in order to keep the stock $($if T did not work for C for $2$ years T was required to return the stock to C$.$ T did work for C for $2$ years, and on December $30,2022(2$ years$)$ the C shares had a FMV of $$975$ per share. On June $30,2023,$ when C stock had a FMV of $$950$ per share, I gifted the $100$ C shares to T$\text{'}$s son $\text{'}$S $).$ On January $2,2025.$ S sold the $100$ C shares for $$1,025$ per share $($$$102,500$ total$).$