Legal Opinion

Evan and Carol Marcus v. Commissioner

United States Tax Court

Decided August 15, 2007No. 10679-05Unknown

1Opinion of the Court

129 T.C. No. 4

UNITED STATES TAX COURT EVAN AND CAROL MARCUS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10679-05. Filed August 15, 2007. In a series of transactions between 1998 and 2000, P exercised incentive stock options (ISOs), acquiring 40,362 shares of V stock. In 2001, Ps sold 30,297 V shares for $1,688,875. Ps had a regular tax basis in these shares equal to the exercise price, $127,920. Ps had an adjusted alternative minimum tax (AMT) basis in these shares equal to the exercise price increased by the amount included in alternative minimum taxable income…

2Cases cited6 opinions

  1. Allen v. Comm'rUnited States Tax Court · 2002
  2. Montgomery v. Comm'rUnited States Tax Court · 2006
  3. Tanner v. Comm'rUnited States Tax Court · 2001
  4. Merlo v. Comm'rUnited States Tax Court · 2006
  5. Erfurth v. CommissionerUnited States Tax Court · 1981

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