Chi Wai - Page 1

                                 T.C. Memo. 2006-179                                  

                               UNITED STATES TAX COURT                                

                       CHI WAI, Petitioner v. COMMISSIONER OF                         
                            INTERNAL REVENUE, Respondent                              

               Docket No.  19316-04L.           Filed August 29, 2006.                

                    P incurred alternative minimum tax liability as a                 
               result of her exercise of incentive stock options in                   
               2000.  The stock declined precipitously in value after                 
               the date of exercise.  P partially paid her year 2000                  
               tax liability through withholding, estimated tax                       
               payments and application of a small credit, and                        
               submitted an offer-in-compromise for the unpaid                        
               balance.  The IRS rejected the offer-in-compromise and                 
               notified P of its intent to levy on P’s property.                      
               Held:  it was not an abuse of discretion to reject P’s                 
               offer.  IRS may proceed with the levy.  Speltz v.                      
               Commissioner, 124 T.C. 165 (2005), affd. 454 F.3d 782                  
               (8th Cir. 2006), followed.                                             

               John S. Harper, for petitioner.                                        
               Cleve Lisecki, for respondent.                                         

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011