124 T.C. No. 9
UNITED STATES TAX COURT
RONALD J. AND JUNE M. SPELTZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15382-03L. Filed March 23, 2005.
Ps incurred AMT liability as a result of their
exercise of incentive stock options in 2000. The stock
declined precipitously in value after the date of
exercise. Ps partially paid the tax liability and
submitted an offer in compromise with respect to the
unpaid balance. The IRS rejected the offer in
compromise and filed a lien on Ps’ property. Held: It
was not an abuse of discretion to reject Ps’ offer in
compromise and to continue the lien.
Timothy J. Carlson, for petitioners.
Albert B. Kerkhove and Stuart D. Murray, for respondent.
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