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

The United States Tax Court finds no IRS Abuse of Discretion by Declining Collection Alternatives and Denying a Face-to- Face Hearing and Upholds IRS Collection Actions Against an Individual

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 United States Tax Court upheld an IRS collection determination against an individual, finding that the Appeals settlement officer verified that all requirements of applicable law and administrative procedure were met, and didn’t abuse his discretion by declining to consider collection alternatives or by denying a face-to-face collection due process hearing.

DORA E. CAUDLE,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-196  

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

The United States Tax Court Finds No Abuse of Discretion by Appeals Settlement Officer Sustaining Federal Tax Lien

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 United States Tax Court held that a settlement officer did not abuse her discretion by denying a collection alternative and sustaining a federal tax lien against an individual, finding that the individual failed to provide evidence disputing his tax liabilities and failed to provide requested financial information.

JAMES A. WALKER, P.A.,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-187

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

The United States Tax Court Upholds Deficiency, Notice of Federal Tax Lien and No IRS Abuse of Discretion Found

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 United States Tax Court, in a summary opinion, affirmed an assessment of income tax deficiency and sustained a notice of federal tax lien because the Tax Court found no abuse of discretion by the IRS, noting that the taxpayer had a prior opportunity to contest his tax liability but neglected to do so.

BRIAN CRAIG JOHNSON,

Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Summ. Op. 2014-90

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

The United States Tax Court Finds No Abuse in IRS’s Decision to Sustain Levy

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 United States Tax Court, in a summary opinion, held that an IRS settlement officer did not abuse her discretion by sustaining a notice of intent to levy against an individual, finding that the individual failed to provide requested financial information or to show he would be unable to pay his tax liability within the collection limitations period.

ALLAN L. BLANK, Petitioner

v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

T.C. Summ. Op. 2014-86