- 2 -
result, P argues that he may use his capital losses
realized in 2001 to reduce his alternative minimum
taxable income in 2000.
Held: The capital loss limitations of I.R.C.
secs. 1211 and 1212 apply for purposes of calculating
alternative minimum taxable income.
Held, further: P’s capital losses realized in 2001
do not create an ATNOL that can be carried back to
reduce his alternative minimum taxable income in 2000.
Don Paul Badgley, Brian G. Isaacson, and Duncan C. Turner,
for petitioner.
Julie L. Payne and Kirk M. Paxson, for respondent.
OPINION
HAINES, Judge: Respondent determined deficiencies in
petitioner’s Federal income taxes of $4,833 and $169,510 for the
years 1999 and 2000, respectively. After concessions,1 the
issues for decision are: (1) Whether the capital loss
limitations of sections 1211 and 1212 apply to the calculation of
alternative minimum taxable income (AMTI); and (2) whether
1 Petitioner concedes respondent’s disallowance of a loss
of $21,871 claimed on Schedule E, Supplemental Income and Loss,
in 1999 and respondent’s allowance of additional itemized
deductions of $6,797 in 1999.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011