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officer discussed the exercise by petitioners of certain incen-
tive stock options (ISO) and the effect of the alternative
minimum tax (AMT) on the tax consequences with respect to such
exercise. During the May 24, 2005 conference, petitioners agreed
that they owe the tax due shown in (1) petitioners’ 2000 return
as amended by petitioners’ amended 2000 return and (2) their 2001
return. However, petitioners claimed at that conference that the
AMT is unfair and that they are entitled to certain carryforward
credits. During the May 24, 2005 telephonic conference, the
settlement officer discussed collection alternatives with peti-
tioners and concluded that they had the ability to pay in full
from retirement and other assets petitioners’ unpaid 2000 liabil-
ity and petitioners’ unpaid 2001 liability. During that confer-
ence, petitioners advised the settlement officer that they did
not wish to submit another offer-in-compromise since respondent
had rejected the one that they had previously submitted in
response to the respective notices of intent to levy that they
received with respect to their taxable years 2000 and 2001.
Petitioners further indicated to the settlement officer during
the May 24, 2005 telephonic conference that they did not wish to
propose an installment agreement. The settlement officer told
petitioners during that conference that she intended to research
recent court cases addressing petitioners’ claim that the AMT is
unfair and that they are entitled to certain carryforward cred-
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Last modified: May 25, 2011