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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.
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Last modified: May 25, 2011