Case: District Court Grants Default Judgment Against Taxpayers for Unpaid Levy (IRC §6332)

A District Court entered a default judgment against the taxpayers for failing to comply with an IRS levy. A corporation failed to pay employment taxes and penalties assessed by the IRS. The IRS levied taxes against the taxpayers who had purchased the corporation’s business assets. Taxpayers initially made levy payments but later stopped making them. The court held that the government sufficiently alleged the taxpayers had property subject to an IRS levy and failed to surrender it upon demand, making them personally liable under I.R.C. §6332(d). The court found the Eitel factors weighed in favor of default judgment, as the ...