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SPELTZ v. COMMISSIONER

Docket No. 15382-03L.

124 T.C. 165 (2005)

124 T.C. No. 9

RONALD J. AND JUNE M. SPELTZ, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 23, 2005.

Attorney(s) appearing for the Case

Timothy J. Carlson, for petitioners.

Albert B. Kerkhove and Stuart D. Murray, for respondent.

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...

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