Dotson v. Commissioner of Revenue

Kenneth Dotson, the taxpayer, appeals from a decision of the Appellate Tax Board (board) affirming the denial by the Commissioner of Revenue (commissioner) of an abatement of personal income taxes for the tax year ending on December 31, 1999. G. L. c. 58A, § 13. On January 22, 1999, Dotson exercised certain options for the purchase of stock in the Amazon.com corporation (Amazon) and achieved a gain of $5,317,145.35 for its immediate sale (disputed income). The commissioner determined him to be a domiciliary of the Commonwealth at the time of realization of the stock proceeds, and assessed…