Ronald J. Speltz June M. Speltz v. Commissioner of Internal Revenue

SMITH, Circuit Judge.

Appellants Ronald and June Speltz (“Taxpayers”) incurred substantial tax liability under the alternative minimum tax (“AMT”) after exercising an incentive stock option. After the time of exercise, the stock value greatly declined. However, the tax liability remained. Taxpayers paid a portion of their tax liability and later made an offer-in-compromise (“OIC”) to settle the balance. The Internal Revenue Service (“IRS”) rejected the OIC. Taxpayers then appealed to the United States Tax Court, which granted summary judgment to the IRS. We affirm.

I. Background

Ronald Speltz…