Attorney’s Failure to File Returns Sinks Bid for IRS Compromise

The IRS appeals office acted within its discretion upholding a proposed levy to collect an attorney’s unpaid income tax, the US Tax Court said Wednesday.

John A. Hartmann sought to participate in multiple alternatives for the IRS to recover his liability, but the agency’s appeals office deemed him ineligible for each option because he hadn’t filed all his required returns, nor was he current on estimated tax payments. The Tax Court sustained those determinations after Hartmann challenged them as an abuse of discretion.

• Hartmann told the Tax Court that the end of his collection due process hearing was unwarranted because ...