- 12 - respondent’s Office of Appeals for consideration of petitioners’ amended return. During the remand, respondent audited petitioners’ original and amended returns and issued to petitioners a Supplemental Notice of Determination under section 6330 and a notice of deficiency under section 6213(a).6 In the notice of deficiency, respondent determined (1) petitioners failed to report the correct amount of wages and capital gains arising from the exercise of petitioner’s ISOs, (2) petitioners were not entitled to certain itemized deductions, (3) petitioners were liable for AMT in excess of that reported on their original return, and (4) petitioners were liable for an accuracy-related penalty. Specifically, respondent determined that petitioners’ correct tax liability for 2000 totaled $3,248,961--a sum comprising regular tax of $2,511,949 and AMT of $737,012. Petitioners filed a petition for redetermination in this case challenging the notice of deficiency. At the conclusion of the trial in this case, the Court directed the parties to file seriatim briefs. After petitioners filed their opening brief, respondent filed an answering brief and a motion for leave to file amended answer seeking an increased deficiency and an increased accuracy-related penalty to conform the pleadings to testimony offered by petitioner at 6 Petitioners’ collection review case at docket No. 16864- 02L was stayed pending the disposition of the instant case.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011