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its.
After the May 24, 2005 telephonic conference, the settlement
officer considered petitioners’ claim to certain carryforward
credits. As part of that consideration, the settlement officer
learned that Congress was considering proposed legislation to
address the ISO/AMT situation but had not enacted any law to deal
with that situation. As part of the settlement officer’s consid-
eration of petitioners’ claim to carryforward credits to their
taxable years 2000 and 2001, she also reviewed the Court’s
opinion in Speltz v. Commissioner, 124 T.C. 165 (2005), affd. 454
F.3d 782 (8th Cir. 2006).
On August 23, 2005, the settlement officer held a face-to-
face Appeals Office hearing with petitioners (August 23, 2005
hearing). At that hearing, petitioners and respondent discussed
the proposed legislation pending in Congress that addressed the
ISO/AMT situation. They exchanged views as to whether petition-
ers would be able to submit an offer-in-compromise to respondent
in which they would claim certain carryforward credits as set
forth in that proposed legislation and would request abatement
for public policy reasons of the remainder of petitioners’ unpaid
2000 liability and petitioners’ unpaid 2001 liability. Petition-
ers also requested at the August 23, 2005 hearing that respondent
abate the additions to tax and interest that respondent assessed
with respect to their taxable years 2000 and 2001. The settle-
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Last modified: May 25, 2011