Case: No Abuse of Discretion in Denying Collection Alternatives Where Taxpayer Not in Compliance with Estimated Tax Obligations (T.C. Memo) (IRC §6330)

Collections due process settlement officer did not abuse her discretion in denying Taxpayer’s proposed collection alternatives and declining to provide Taxpayer additional time to respond to requests because Taxpayer consistently failed to comply with his current year estimated tax obligations, the U.S. Tax Court held, affirming the proposed collection action and granting the IRS’s motion for summary judgment. Despite the settlement officer informing Taxpayer of the importance of keeping current with estimated tax obligations for the consideration of collection alternatives, the settlement officer still gave numerous extensions for substantiation and compliance. The court held that it was not an abuse ...