Case: Settlement Officer’s Determination Affirmed After Radio Silence From Petitioners; NFTL Sustained (T.C. Memo) (IRC §6330)

A settlement officer did not abuse her discretion when, after receiving no response from Petitioners, she sustained the filing of a notice of federal tax lien (NFTL), the U.S. Tax Court held in a memorandum opinion. Petitioners, a married couple, were on an installment agreement with the IRS for several years of income tax liabilities and penalties. In 2019, the IRS terminated the installment agreement for noncompliance and filed an NFTL. After Petitioners requested a collection due process (CDP) hearing, an IRS settlement officer issued a scheduling letter which set the hearing date and requested their financial information. Petitioners did ...