Case: Proposed Levy Properly Sustained Against Unresponsive Taxpayers (T.C. Memo) (IRC §6330)

The IRS Independent Office of Appeals (Appeals) did not abuse its discretion in sustaining a proposed levy to collect taxpayers’ unpaid income tax liabilities, the U.S. Tax Court held, upholding the Notice of Determination issued by Appeals and granting the government’s motion for summary judgment. Petitioners, a married couple, requested a collection due process hearing after receiving a notice of intent to levy for unpaid taxes from 2017 and 2018. They sought an installment agreement and time to obtain a home equity loan to pay the tax debt. The Appeals Officer allowed several months for Petitioners to provide proof of ...