- 8 - income of $244,190 rather than the $20,243,699 initially reported. Other than wage income, the 2000 amended return reported the same income and deductions as initially reported, resulting in regular taxable income of $3,997,850. The 2000 amended return reported a reduced regular tax of $852,586, AMT of zero, self-employment tax of $429, and after deducting the same foreign tax credit and total payments as initially reported, claimed a refund of $4,815,148. The 2000 amended return was not accepted by the Internal Revenue Service. On April 15, 2003, petitioner filed a separate Form 1040X for 2000 containing the following statement: The taxpayer’s original return erroneously reported an amount due based on an incorrect valuation and/or inclusion of stock options (both qualified and non qualified) and the incorrect application of the AMT net operating loss and AMT credit. A list of the legal grounds supporting the amended return’s valuation of stock options and/or exclusion of such options from income along with the correct application of the AMT net operating loss and AMT credit is attached to this form. The application of the attached legal arguments to the taxpayer’s stock option transactions will result in a change in the amount due for lines 1, 5 through 10, and 19 through 24 on the front of this 1040X form. The exact amount of the refund will be determined pending the final determination of facts and the release of a technical advice memo or court decision. 4(...continued) rules or regulations or to a substantial understatement of income tax for non-tax-shelter items if the return position has a reasonable basis.Page: 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