- 8 - 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, anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011