United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court held that the IRS didn’t abuse its discretion in sustaining a proposed levy action against a taxpayer for trust fund recovery penalties under section 6672 because the settlement officer determined that the taxpayer had a reasonable collection potential far in excess of the amount offered in compromise.

KENNETH M. MOORE,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2013-278

United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court remanded to the Appeals Office an individual’s challenge to an IRS levy, finding that the IRS must clarify whether a notice of deficiency was properly issued and mailed to the individual to determine whether the IRS has a right to collect the unpaid tax.

WILLIAM B. MEYER,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T. C. Memo. 2013-268