- 4 - On December 21, 2000, petitioner exercised an option to purchase 46,125 shares of Exodus common stock at 20 cents per share, for a total exercise price of $9,225. The price of the optioned stock on the NASDAQ on December 21, 2000, was $23.3125 per share, for a total fair market value of $1,075,289 on the date of exercise. Petitioner was not a dealer in securities but instead was acting as an investor when he exercised the ISOs. Exodus filed for bankruptcy on September 26, 2001. In a press release dated November 21, 2001, Exodus announced that the company’s common stock had no value. Petitioner’s shares of Exodus stock were worthless as a result of Exodus’s bankruptcy. Petitioner timely filed a Federal income tax return for 2000. On the return, petitioner reported $248,585 in wages, $432 in taxable interest, $11,311 in dividends, and $319,614 in capital gain, for total income of $579,942. Petitioner claimed itemized deductions of $31,213 and reported taxable income of $548,729 and regular tax liability of $134,455. Petitioner also reported alternative minimum tax (AMT) liability of $116,973, for a total tax of $251,428. Attached to petitioner’s 2000 tax return was Form 6251, Alternative Minimum Tax--Individuals. On line 10, petitioner reported excess AMTI over regular tax income of $452,025 as a result of his exercise of the Exodus ISOs. Instead of using the spread between the exercise price and the fair market value ofPage: 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