127 T.C. No. 9 UNITED STATES TAX COURT JONATHAN N. AND KIMBERLY A. PALAHNUK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12015-05. Filed October 11, 2006. In 2000, P acquired stock through his exercise of an incentive stock option (ISO) within the meaning of sec. 422(b), I.R.C. P realized no income or loss on the exercise for purposes of computing Ps’ 2000 taxable income but realized $2,086,009 of income for purposes of computing Ps’ 2000 alternative minimum taxable income (AMTI). In 2001, P sold the stock and realized on the sale a regular tax capital gain of $148,461 and an alternative minimum tax (AMT) capital loss of $1,937,547. During 2001, P also realized $153,625 of capital losses unrelated to any ISO. Ps calculated their 2001 taxable income by including $3,000 of their regular tax capital loss resulting from all of the sales. Ps argue that they may calculate their 2001 AMTI by reducing their 2001 taxable income by the $2,086,009 difference (as rounded) between the $148,461 regular tax capital gain and $1,937,547 AMT capital loss attributable to the stock related to the ISO. Ps argue alternatively that their 2001 AMTI is calculated by reducing their 2001 taxable income by the $151,461Page: 1 2 3 4 5 6 7 8 9 10 Next
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