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Appeals will not consider the
principles under IRC 6015(f) in
determining whether or not the ETA-
OIC should be accepted from Mrs.
Wai.
The offer is being rejected without further consideration by
Appeals at this time.
During the pendency of petitioner’s CDP matter before
respondent’s settlement officer, petitioner’s counsel was in
contact with other Government officials (of which he kept the
Settlement Officer and her superior informed) in an attempt to
obtain collateral relief for petitioner from her AMT liability.
At various times, counsel was in contact with the National
Taxpayer Advocate’s Office, and with the Assistant Secretary of
Treasury for Tax Policy.
By letter dated October 28, 2004, Commissioner of Internal
Revenue Mark W. Everson advised Senators Grassley and Baucus
that, as of that date, no formal guidance had been issued by the
IRS to its employees specifically pertaining to the compromise of
liabilities attributable to the AMT arising from the exercise of
ISOs.
Discussion
The facts in this case giving rise to the AMT almost exactly
parallel those of Speltz v. Commissioner, 124 T.C. 165 (2005),
affd. 454 F.3d 782 (8th Cir. 2006). In each case, the taxpayer
exercised ISOs during the year 2000, and reported on the
respective Federal tax returns, for purposes of the AMT, an
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