Kadillak v. Commissioner of Internal Revenue

OPINION

BRUNETTI, Circuit Judge:

Taxpayer Anthony Kadillak appeals a tax court decision upholding the Commissioner of Internal Revenue’s determinations of his income tax liabilities for tax years 2000 and 2001. The case concerns Kadillak’s acquisition, and later forfeiture and sale, of vested and nonvested shares of stock through the exercise of incentive stock options (“ISOs”), and the tax consequences of those transactions, especially for purposes of the Alternative Minimum Tax (“AMT”). In denying Kadillak’s petition for review, the tax court determined that Kadillak’s election under I.R.C. §…