Legal Opinion

Marcus v. Comm'r

United States Tax Court

Decided August 15, 2007No. 10679-05Published

In a series of transactions between 1998 and 2000, P exercised incentive stock options (ISOs), acquiring 40,362 shares of V stock.

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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 (AMTI) by reason of the exercise of the ISOs, $ 4,472,288. Ps argue that the difference between the adjusted AMT basis and the regular tax basis of the V shares sold…

1Opinion of the Court

EVAN AND CAROL MARCUS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Marcus v. Comm'r

No. 10679-05

United States Tax Court

129 T.C. 24; 2007 U.S. Tax Ct. LEXIS 22; 129 T.C. No. 4;

August 15, 2007, Filed

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…

2Cases cited7 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. Merlo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2007

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