Legal Opinion

Humphrey v. Comm'r

United States Tax Court

Decided November 9, 2006No. 19295-03LUnpublished

P-H, as vice president of i2 Technologies, Inc. (i2), received incentive stock options (ISOs). On Dec. 31, 1999, P-H resigned as i2's senior vice president of marketing. On Nov. 13, 2000, P- H exercised many of his ISOs. Ps filed a joint Federal income tax return for 2000, wherein they reported ordinary gain for regular income tax purposes from the exercise of the ISOs and reported a regular income tax of $ 8,772,392. Ps did not fully pay the tax liability.

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P-H, as vice president of i2 Technologies, Inc. (i2), received incentive stock options (ISOs). On Dec. 31, 1999, P-H resigned as i2's senior vice president of marketing. On Nov. 13, 2000, P- H exercised many of his ISOs. Ps filed a joint Federal income tax return for 2000, wherein they reported ordinary gain for regular income tax purposes from the exercise of the ISOs and reported a regular income tax of $ 8,772,392. Ps did not fully pay the tax liability. Ps subsequently submitted to R an amended return for 2000 in which they claimed they were not subject to regular income tax upon the…

1Opinion of the Court

ROBERT C. AND PATRICIA C. HUMPHREY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Humphrey v. Comm'r

No. 19295-03L

United States Tax Court

T.C. Memo 2006-242; 2006 Tax Ct. Memo LEXIS 246; 92 T.C.M. (CCH) 417;

November 9, 2006, Filed

P-H, as vice president of i2 Technologies, Inc. (i2), received

incentive stock options (ISOs). On Dec. 31, 1999, P-H resigned

as i2's senior vice president of marketing. On Nov. 13, 2000, P-

H exercised many of his ISOs.

Ps filed a joint Federal income tax return for 2000, wherein

they reported ordinary gain for regular income tax purposes from

the exercise of…

2Cases cited14 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Montgomery v. Comm'rUnited States Tax Court · 2004
  4. Simpson v. CommissionerUnited States Tax Court · 1975
  5. United States v. W. M. Webb, Inc.Supreme Court of the United States · 1970

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