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

United States Tax Court Upholds Lien, Levy Actions Against Tax Scheme Promoter, and Finds No IRS Abuse of Discretion

The  United States Tax Court found no IRS Abuse of Discretion by an Appeals Settlement Officer and upheld IRS lien and levy actions against an individual who promoted and sold abusive tax schemes, finding that she wasn’t entitled to challenge the underlying liabilities because the individual didn’t participate in the collection proceedings or provide a collection alternative.

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.

KATHLEEN KAHN,
Petitioner(s),
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

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

No IRS Abuse of Discretion in Denying Non-compliant Couple’s Installment Agreement

The United States Tax Court held that an IRS settlement officer didn’t abuse her discretion by rejecting a couple’s proposed installment agreement and sustaining a proposed levy action, finding that the couple failed to make sufficient estimated tax payments, was not in compliance with current tax obligations, and had a history of noncompliance.

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.

ANDREW M. HULL AND VICKIE J. HULL,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2015-86