Jonathan N. and Kimberly A. Palahnuk v. Commissioner

127 T.C. No. 9

UNITED STATES TAX COURT JONATHAN N. AND KIMBERLY A. PALAHNUK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12015-05. Filed October 11, 2006. 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…