Dino Co is a start-up company that employs Ross as a palaeontologist. In January 2020, Dino Co issues Ross, for no consideration, rights to acquire 10,000 shares in the company for $3 per share under an ESS. At the time the rights were issued, the market value of each share in Dino Co was $2. Assume that the ESS meets all the requirements for the start-up concession ins 83A-33. In October 2022, Ross exercises the rights and acquires 10,000 shares in Dino Co for $30,000. At the time of exercising the rights, the shares in Dino Co have a market value of $8 per share. Six months later Ross sells the 10,000 shares in Dino Co to Rachel for $84,000. Advise Ross of the tax implications of the transactions. [1[22.3]