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MARCUS v. COMMISSIONER

Docket No. 10679-05.

129 T.C. 24 (2007)

129 T.C. No. 4

EVAN AND CAROL MARCUS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 15, 2007.

Attorney(s) appearing for the Case

Don Paul Badgley and Brian G. Isaacson, for petitioners.

Julie L. Payne, for respondent.

OPINION

HAINES, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes of $491,829 and $178,664 for the years 2000 and 2001 (years at issue), respectively. After concessions,1 the issue for decision is whether petitioners may increase their 2001 alternative tax net operating loss (ATNOL) by the difference between the adjusted alternative minimum tax (AMT) basis and the regular tax basis of stock...

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