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$625,000 Check to IRS Was Payment Blocking Access to Tax Court

Dec. 28, 2021, 10:03 PM

A $625,000 check to the IRS was a payment rather than a deposit against IRS-assessed liabilities, and so the taxpayer can’t challenge the underlying liabilities at the U.S. Tax Court, the court ruled.

Faisal Ahmed sent the check in response to about $617,000 in trust fund recovery penalty liabilities the IRS assessed against him, arguing it was a deposit made to get an IRS lien against him discharged. While Ahmed conceded that the check didn’t constitute a deposit under tax code Section 6603, which allows cash deposits to stop interest from running on unassessed tax underpayments, he ...