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amended returns. Your claim for refund is under
consideration in Appeals and will be submitted
sustaining the application of the AMT in 2000 and
proposing abatement of the AMT for 2001.
Incentive stock options were issued to you by Cisco
Systems as part of your compensation for services. You
exercised the options in 2000 and 106,560 shares of
Cisco stock were transferred to you unconditionally and
without restriction. The * * * [AMT] liability
produced by these transactions attaches to the year
2000.
The lien notice stated:
Addressing Efficient Collection with Concern Over the
Intrusiveness of Collection
Internal Revenue Manual 5.12.1.13 provides for the
filing of a Notice of Federal Tax Lien for balances due
of over $5,000.00.
The lien is intrusive but it is appropriate in this
instance to protect the government’s interest. You
have made no payments toward either 2000 or 2001 and
there is no indication that the liability for 2000 will
be paid voluntarily. In terms of alternatives to
collection, you have filed an * * * [OIC] based on
doubt as to liability, doubt as to collectibility, and
effective tax administration. That offer is being
rejected on all three grounds. It is the Service’s
position that ultimately there will be no AMT liability
for 2001. However, until the issue is finally decided
in the various venues to which you have turned for
relief the lien continues to be appropriate.
The levy notice stated:
Addressing Efficient Collection with Concern Over the
Intrusiveness of Collection
IRC Section 6330(c)(3)(C) requires that the
determination by an Appeals Officer under this
subsection shall take into consideration whether any
proposed collection action balances the needs for the
efficient collection of taxes with the legitimate
concern of the taxpayer that any collection action be
no more intrusive than necessary.
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Last modified: November 10, 2007