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 United States Tax Court upheld the IRS Appeals Office’s decision to proceed with a proposed levy to collect an individual’s income tax liabilities, finding that he was barred from challenging the existence or amounts of his underlying tax liabilities and that the IRS didn’t abuse its discretion in denying his request for an installment agreement.

ROBERT ALAN LYONS,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-32