Ronald J. and June M. Speltz v. Commissioner

124 T.C. No. 9

UNITED STATES TAX COURT RONALD J. AND JUNE M. SPELTZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15382-03L. Filed March 23, 2005. 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…