Case: Settlement Officer Did Not Abuse Discretion in Denying Request for Penalty Abatements and Consideration of Collection Alternatives (T.C. Memo) (IRC §6330)

Settlement officer (SO) with the IRS Independent Office of Appeals (Appeals) did not abuse her discretion in determining Petitioner was not entitled to abatement of previously assessed additions to tax or consideration of collection alternatives for his outstanding tax liability, the U.S. Tax Court held in a memorandum opinion, granting the government’s motion for summary judgment. Petitioner requested a collection due process hearing after Appeals upheld the IRS’s levy notice with respect to unpaid taxes and additions to tax for tax years 2010, 2011, and 2012, but failed to respond at trial to the government’s motion. Nevertheless, the court considered ...