-10- regular tax ISO gains of $148,461) and an AMT capital loss of $2,091,170 (the sum of the non-ISO losses of $153,625 and the AMT ISO losses of $1,937,547). The recognition of both the regular tax capital loss and the AMT capital loss is limited to $3,000, see sec. 1211(b); see also Merlo v. Commissioner, supra (section 1211(b) limits an individual’s annual deduction of an AMT capital loss to $3,000), which, in turn, means that petitioners’ adjustment under section 56(b)(3), representative of the difference between the recognized losses for regular tax and AMT purposes, is zero as determined by respondent. We sustain respondent’s determination. In so doing, we have considered all of petitioners’ arguments and conclude that those arguments not discussed herein are without merit. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011