United States Tax Court Upholds Levy Action, Rejection of Installment Agreement, and Finds No IRS Abuse of Discretion
The United States Tax Court held that an IRS settlement officer in the Appeals Office didn’t abuse his discretion by rejecting a couple’s proposed installment agreement and sustaining a levy action against them because they had sufficient equity in their assets to pay the taxes, they failed to offer acceptable collection alternatives, and they 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.
RANDY TILLERY AND RACHEL BENATOR,
COMMISSIONER OF INTERNAL REVENUE,
T.C. Memo. 2015-170