- 10 - On March 22, 2003, petitioner filed a Form 1040X amending his 2001 Federal income tax return (2001 amended return) together with an attached Form 8275. The return was prepared by Mr. Isaacson and was initially accepted by the IRS. It reported the same regular income and itemized deductions as the original 2001 return. However, unlike the original 2001 return, the 2001 amended return reflected petitioner’s assertion that the section 83(b) election made in 2000 was invalid as to the nonvested shares. As a result, the amended return reported $340,213 of AMTI, which was the spread between FMV and the exercise price for the Ariba stock granted under option No. 117, which vested in petitioner throughout the 2001 tax year. After deducting a $12,720 payment, the return reported a total tax liability of $88,125 consisting entirely of AMT. Petitioner failed to remit the full amount of tax due with his amended return. Respondent assessed a tax liability of $100,845 for 2001 and sent a notice of balance due on May 19, 2003. Petitioner has not fully paid the balance. 3. Other Amended Returns for 2000 and 2001 Petitioner filed additional Forms 1040X for 2000 and 2001 based upon Mr. Isaacson’s advice. Each Form 1040X was prepared by Mr. Isaacson and included Form 8275, although neither was accepted by the IRS. The 2000 Form 1040X Explanation of Changes to Income, Deductions and Credits stated: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