Robert C. and Patricia C. Humphrey - Page 3

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          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 of               






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