- 3 - OPINION HAINES, Judge: Petitioner filed a petition with this Court in response to Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 for 2000 and 2001 (years at issue). Pursuant to section 6330(d), petitioner seeks review of respondent’s determinations.1 The remaining issues for decision are: 1. Whether petitioner’s section 83(b) election for 2000 was valid. This Court holds the section 83(b) election was valid. 2. Whether petitioner is entitled to an alternative minimum tax (AMT) ordinary loss pursuant to section 1341 for stock forfeited under a lapse provision. This Court holds he is not so entitled. 3. Whether petitioner may carry back capital losses pursuant to section 1211 to reduce the amount of his alternative minimum taxable income (AMTI) for 2000. This Court holds he may not. 4. Whether petitioner may carry back alternative minimum tax net operating losses (AMTNOL) to reduce the amount of his AMTI for 2000. This Court holds he may not. 1 Unless otherwise indicated, all section references are to the Internal Revenue Code (Code), as amended. All Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. Amounts are rounded to the nearest dollar.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