KADILLAK v. C.I.R.

No. 07-70600.

534 F.3d 1197 (2008)

Anthony J. KADILLAK, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed July 29, 2008.


Attorney(s) appearing for the Case

Don Paul Badgley, Badgley-Mullins Law Group, Seattle, WA; and Brian G. Isaacson, Merriam & Isaacson, Seattle, WA, for the petitioner-appellant.

Francesca U. Tamami and Richard Farber, Tax Division, U.S. Department of Justice, Washington, D.C., for the respondent-appellee.

Before: MELVIN BRUNETTI, RONALD M. GOULD, and CONSUELO M. CALLAHAN, Circuit Judges.


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...

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