Case: Notice of Federal Tax Lien Filing Against Attorney Properly Sustained (T.C. Memo)

The IRS did not abuse its discretion in sustaining a Notice of Federal Tax Lien filing against the taxpayer, held the U.S. Tax Court, granting summary judgment for the IRS. Taxpayer, an attorney, had unpaid tax liabilities for tax years 2016-2019 based on self-filed returns. The IRS filed a Notice of Federal Tax Lien and issued a notice of intent to levy. Taxpayer requested a Collection Due Process (CDP) hearing regarding the lien but not the levy. At the hearing, the Appeals Officer verified legal requirements were met, considered collection alternatives, and offered two installment agreement options based on taxpayer’s ...