-2- Held: The difference between the adjusted AMT basis and the regular tax basis of stock received through the exercise of an ISO is not a tax adjustment taken into account in the calculation of an ATNOL in the year the stock is sold. Don Paul Badgley and Brian G. Isaacson, for petitioners. Julie L. Payne, for respondent. OPINION HAINES, Judge: Respondent determined deficiencies in petitioners’ Federal income taxes of $491,829 and $178,664 for the years 2000 and 2001 (years at issue), respectively. After concessions,1 the issue for decision is whether petitioners may increase their 2001 alternative tax net operating loss (ATNOL) by the difference between the adjusted alternative minimum tax (AMT) basis and the regular tax basis of stock received through the exercise of incentive stock options (ISOs) in 2000, but sold in 2001. 1Respondent concedes that petitioners are not liable for accuracy-related penalties under sec. 6662 for the years at issue, and that petitioners’ 2001 capital gain will be reduced by $58,244. Petitioners concede that they are required to report additional capital gain of $15,147 for 2000.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007