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
OPINION
Cohen, Judge:
This case is before the Court on respondent’s motion for summary judgment, seeking a determination sustaining an Appeals officer’s rejection of petitioners’ offer in compromise. Petitioners seek a summary determination that it was an abuse of discretion to refuse their offer in compromise because of the unfair application of the alternative minimum tax (amt) based on their exercise of incentive stock options (isos) where the stock acquired by exercise of the ISOs has lost substantially all of its value subsequent to the acquisition of the stock. Unless otherwise indicated,…
2Cases cited18 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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3Cited by55 opinions
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