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.
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