Daily Tax Report ®

Case: No Abuse of Discretion in Sustaining Levy (T.C. Summ.) (IRC §6321)

Jan. 14, 2020, 5:00 AM

Settlement officer did not abuse her discretion by sustaining levy where Taxpayer failed to provide sufficient information during the collection due process hearing regarding the amount of his underlying liability, and made minimal effort in cooperating with reasonable requests for information to determine collection alternatives, the U.S. Tax Court held in a nonprecedential summary opinion. Taxpayer argued that a change in alimony was a change of material fact that changes his tax liability for the years in question, but the court rejected that argument by finding that as a cash basis taxpayer, repayment in a later year of an overpayment...

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