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SPELTZ v. C.I.R.

No. 05-3054.

454 F.3d 782 (2006)

Ronald J. SPELTZ; June M. Speltz Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eighth Circuit.

Filed: July 14, 2006.

Attorney(s) appearing for the Case

Dirk J.J. Suringa, argued, Washington, D.C. (Timothy J. Carlson, Arlington, VA, on the brief), for appellant.

Regina S. Moriarty, argued, Tax Division, Dept. of Justice, Washington, D.C. (Jonathan S. Cohen, Tax Division, Dept. of Justice, D.C., on the brief), for appellee.

Before LOKEN, Chief Judge, BOWMAN, and SMITH, Circuit Judges.

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...

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