- 10 - However, for AMT purposes, petitioner must include in his AMTI the spread between the exercise price and the fair market value of the shares of Exodus stock on the date of exercise. See secs. 55(b)(2), 56(b)(3), 83(a). We find that petitioner must include $1,066,064 in his AMTI for 2000.6 As a result, petitioner’s adjusted AMT basis in the shares of Exodus stock is increased by the amount recognized to $1,075,289. Next, we consider whether petitioner may reduce his AMTI in 2000 as a result of the AMT capital loss realized in 2001. B. Capital Losses Under Regular Tax and Alternative Minimum Tax If securities which are capital assets (as defined by section 1221) become worthless during a taxable year, any losses resulting therefrom are treated as capital losses, as if a sale or exchange of the securities occurred on the last day of that taxable year. Sec. 165(g)(1). Section 165(f) provides that capital losses are allowed only to the extent allowed in sections 1211 and 1212. 5(...continued) his “regular tax basis” and to his basis for AMT purposes as his “adjusted AMT basis”. 6 $1,075,289 (fair market value of petitioner’s shares of exodus stock on 12/21/00) less $9,225 (total exercise price) equals $1,066,064.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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