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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.
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Last modified: May 25, 2011