Pierce v. United States

MEMORANDUM OPINION AND FINAL ORDER

BRADEN, Judge.

Plaintiffs are among a number of employee-taxpayers that exercised incentive stock options and paid the Alternative Minimum Tax (“AMT”)1 at discounts during the robust stock market of the late 1990s and early in 2000. Subsequently, when the market declined, Plaintiffs incurred significant capital losses when they exercised those options. To offset the AMT due, Plaintiffs requested that the Internal Revenue Service (“IRS”) include these capital losses as a negative AMT adjustment and allow Plaintiffs to carry back excess losses to prior tax…