Case: Tax Court Upholds IRS Decision to Enforce Federal Tax Lien for Unpaid Trust Fund Penalties (T.C. Memo)

The U.S. Tax Court held that the Appeals Office did not abuse its discretion in sustaining the filing of a notice of federal tax lien to collect unpaid trust fund recovery penalties, granting summary judgment to the IRS. Taxpayer, the sole owner and officer of a company, was assessed trust fund recovery penalties for unpaid employment taxes. The IRS issued a notice of federal tax lien filing, and the taxpayer requested a collection due process hearing. During the hearing, the taxpayer submitted an offer-in-compromise based on doubt as to collectibility. The settlement officer determined that the taxpayer’s reasonable collection potential ...