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of a notice of Federal tax lien with respect to petitioner’s
unpaid 2000 and 2001 Federal income tax liabilities.
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulated facts into our findings by this reference. Petitioner
resided in Cambridge, Massachusetts, when his petition in this
case was filed.
Petitioner timely filed Forms 1040, U.S. Individual Income
Tax Return, for 2000 and 2001. On his 2000 tax return,
petitioner reported a total tax liability of $105,934, which
included an alternative minimum tax (AMT) liability of $64,675
attributable to his exercise of incentive stock options during
that year.2 Petitioner reported tax due of $72,576 for 2000 and
sent a $10,000 payment with his 2000 return. On his 2001 tax
return, petitioner reported a total tax liability of $77,579 and
a tax due of $70,258. The ordinary income reported on
petitioner’s 2001 return included income from his disposition of
incentive stock options during 2001.3
2Secs. 421 and 422 provide for deferred tax treatment of the
qualifying exercise of an incentive stock option. However, the
favorable tax treatment does not apply for AMT calculation
purposes. Sec. 56(b)(3).
3Deferred tax treatment under secs. 421 and 422 is not
available on the exercise of an incentive stock option if the
taxpayer disposes of the share of stock received pursuant to the
option within 2 years of the grant of the option or within 1 year
of receipt of the share. Sec. 422(a)(1). Petitioner admits that
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