- 4 - owe”, the sum of $1,928,732 was reported. Mrs. Chou’s signature on the return appeared approximately 1-1/2 inches below the line for “amount you owe”. Her occupation was shown as interior designer. On November 19, 2001, petitioners filed an offer-in- compromise (OIC) on “Doubt as to Liability” for 2000, citing pending Federal legislation. On December 6, 2001, while their OIC was pending, the Internal Revenue Service sent them a notice of intent to levy for 2000. They ultimately withdrew their OIC for 2000 based on “Doubt as to Liability”, and, on February 4, 2002, submitted an OIC based on “Effective Tax Administration” or, in the alternative, “Doubt as to Liability with Special Circumstances”. Their OIC was rejected on August 26, 2002, and petitioners sought review by the Appeals Office. On March 20, 2003, the Appeals Office sustained rejection of the OIC for 2000. Petitioners sought judicial review of that rejection more than 30 days after the offer was rejected. Petitioners’ Federal income tax return for 2001 was timely filed in April 2002. On or about July 20, 2003, petitioners filed joint amended returns for 2000 and 2001, claiming that the transaction involving the Cisco shares originally reported on their 2000 tax return should have been reported in 2001. Petitioners explained their position as follows: Taxpayers amend their 2001 personal income tax return to report their * * * [AMT] preference in taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007