Palahnuk v. Comm'r
United States Tax Court
In 2000, P acquired stock through his exercise of an incentive stock option (ISO) within the meaning of sec. 422(b), I.R.C.
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In 2000, P acquired stock through his exercise of an incentive stock option (ISO) within the meaning of sec. 422(b), I.R.C. P realized no income or loss on the exercise for purposes of computing Ps' 2000 taxable income but realized $ 2,086,009 of income for purposes of computing Ps' 2000 alternative minimum taxable income (AMTI). In 2001, P sold the stock and realized on the sale a regular tax capital gain of $ 148,461 and an alternative minimum tax (AMT) capital loss of $ 1,937,547. During 2001, P also realized $ 153,625 of capital losses unrelated to any ISO. Ps calculated their 2001…
1Opinion of the Court
OPINION
Laro, Judge:
This case is before the Court for decision without trial. See Rule 122.1 Petitioners petitioned the Court to redetermine respondent’s determination of a $155,305 deficiency in their 2001 Federal income tax. The deficiency stems from respondent’s disallowance of an adjustment that petitioners made in calculating their 2001 alternative minimum taxable income (AMTI). We decide whether the calculation of petitioners’ 2001 AMTI includes an adjustment for the difference between the 2001 regular tax capital gain and 2001 alternative minimum tax (AMT) capital loss that were…
2Cases cited5 opinions
- Allen v. Comm'rUnited States Tax Court · 2002
- Montgomery v. Comm'rUnited States Tax Court · 2006
- Merlo v. Comm'rUnited States Tax Court · 2006
- Davis v. Comm'rUnited States Tax Court · 2002
- Harbor Cove Marina Ptnrs. P'ship v. Comm'rUnited States Tax Court · 2004
3Cited by10 opinions
- Palahnuk v. CommissionerCourt of Appeals for the Second Circuit · 2008
- Pierce v. United StatesUnited States Court of Federal Claims · 2007
- Guzak v. United StatesUnited States Court of Federal Claims · 2007
- Graev v. Comm'rUnited States Tax Court · 2016
- Jonathan N. and Kimberly A. Palahnuk v. CommissionerUnited States Tax Court · 2006
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