- 7 - made; (6) the amount paid for the stock; and (7) a confirmation that copies of the election were furnished to Ariba. 3. Sale and Repurchase of Stock Petitioner’s employment with Ariba was terminated on April 4, 2001. On May 30, 2001, Ariba gave petitioner notice it was exercising repurchase rights with respect to 6,667 nonvested shares granted under option No. 117 for a total purchase price of $642. On December 30, 2002, petitioner sold to a third party the remaining 25,333 shares granted under option No. 117. All of those shares had vested. B. Income Tax Returns and Assessments 1. Original Federal Income Tax Returns Prepared for 2000 and 2001 Petitioner timely filed his Form 1040, U.S. Individual Income Tax Return, for 2000, which was prepared by a certified public accountant and accepted by the Internal Revenue Service (IRS). The return reported wages of $204,722, capital gains of $691,615, dividend income of $18,135, itemized deductions of $112,744, and taxable income of $801,728. The return also reported AMTI of $4,136,705, $3,260,998 of which consisted of the gain recognized from the receipt of 32,000 vested and nonvested shares of Ariba stock under option No. 117. The return reported a regular tax of $167,139 and an AMT of $932,309 for a total tax liability of $1,099,448. After applying a foreign tax credit of $60 and withholding and estimated tax payments of $135,791, thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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