He presumably would have done so by relying on a special IRS "safe harbor" rulerelating to the taxation of a service partner's receipt of such interests, but that rule emphatically does not apply to an interest when sold to a retirement plan, which is supposed to be measured by its true fair market value.
The AWC alleges that while taking the examination, Cammarota improperly possessed, and used, unauthorized notes relating to the subject matter of the examination, in violation of NASD Rule 1080 and FINRA Rule 2010.