- 4 -
The proceeds petitioner received from the sale of the Veritas
shares totaled $1,267,468.
B. Federal Income Tax Returns
1. 2000 Federal Income Tax Return
Petitioner timely filed his 2000 Federal income tax return,
which was prepared by a certified public accountant. The return
reported wages from Veritas of $137,261, capital gains of
$425,161, miscellaneous income of $8,104, and, after itemized
deductions of $88,844, taxable income of $481,682. The return
reported regular tax of $165,719 and AMT of $898,914 for a total
tax liability of $1,064,611, after deducting a foreign tax credit
of $22.
On June 12, 2002, relying on the advice of Brian G.
Isaacson, a tax attorney, petitioner filed a Form 1040X, Amended
U.S. Individual Income Tax Return, amending his 2000 Federal
income tax return (2000 amended return) with a Form 8275,
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