- 3 - issues for decision are: (1) Whether pursuant to section 422(a)(2) petitioner remained an employee with i2 until 3 months prior to the exercise of his incentive stock options (ISOs); (2) if petitioner remained an employee of i2 until 3 months prior to exercising his ISOs, whether the capital loss limitations of section 1211 apply to the computation of alternative minimum taxable income (AMTI); (3) if petitioner remained an employee of i2 until 3 months prior to exercising his ISOs, whether alternative minimum tax (AMT) capital losses can be carried back as an alternative tax net operating loss (ATNOL) to reduce AMTI. FINDINGS OF FACT The parties’ stipulation of facts and attached exhibits are incorporated herein by this reference, and the facts stipulated are so found. At the time the petition was filed, petitioners resided in Southlake, Texas. A. i2 Employment and Stock Options 1. Employment with i2 Headquartered in Dallas, i2 is a Delaware corporation that develops and markets enterprise chain management solutions, including supply chain software and consulting services. In 1988, i2’s founders created the company’s first software program, which was groundbreaking in the supply chain management industry. On February 3, 1995, petitioner was recruited as i2’s vice president and eventually became i2’s senior vice president ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011