Speltz v. Comm'r
United States Tax Court
Ps incurred AMT liability as a result of their exercise of incentive stock options in 2000. The stock declined precipitously in value after the date of exercise. Ps partially paid the tax liability and submitted an offer in compromise with respect to the unpaid balance. The IRS rejected the offer in compromise and filed a lien on Ps' property. Held: It was not an abuse of discretion to reject Ps' offer in compromise and to continue the lien.
1Opinion of the Court
RONALD J. AND JUNE M. SPELTZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Speltz v. Comm'r
No. 15382-03L
United States Tax Court
124 T.C. 165; 2005 U.S. Tax Ct. LEXIS 9; 124 T.C. No. 9;
March 23, 2005, Filed
Judgment entered for respondent.
Ps incurred AMT liability as a result of their exercise of
incentive stock options in 2000. The stock declined
precipitously in value after the date of exercise. Ps partially
paid the tax liability and submitted an offer in compromise with
respect to the unpaid balance. The IRS rejected the offer in
compromise and filed a lien on Ps' property. Held: It…
2Cases cited19 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Commissioner v. BanksSupreme Court of the United States · 2005
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