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2000, to sell the shares of InsWeb common stock petitioner had
pledged as collateral.
On February 7, 2001, petitioner filed a Form 1040X, Amended
U.S. Individual Income Tax Return, for 1999 claiming a refund of
$108,488. In the amended return petitioner reduced the amount of
wage income from InsWeb by the spread between the fair market
value and the exercise price he paid for shares of stock he
received when he exercised his nonstatutory stock options on
December 30, 1999.
On September 19, 2001, petitioner filed for chapter 7
bankruptcy in the Bankruptcy Court for the Northern District of
California. In his bankruptcy schedules, petitioner listed
Comerica as a creditor. Petitioner also stated in his schedules
that Comerica had filed suit against him to collect on the
promissory note.
Petitioner filed a second Form 1040X for 1999 on August 4,
2003, claiming a refund of $404,537. In the second amended
return petitioner reduced the amount of wage income from InsWeb
by the spread between the fair market value and the exercise
price he paid for shares of stock he received when he exercised
his nonstatutory stock options on September 7 and December 30,
1999.
On October 1, 2003, respondent sent petitioner a notice of
deficiency in which respondent denied petitioner’s claim for
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