Case: Tax Court Upholds IRS Levy Against Taxpayer for Unpaid Income Taxes (T.C. Memo)

The U.S. Tax Court upheld the IRS’s decision to issue a levy against the taxpayer for her unpaid federal income tax liabilities for the years 2014 and 2016, totaling $729,910. The taxpayer, who did not file tax returns from 2013 to 2019, contested the levy after the IRS prepared substitute returns and issued notices of deficiency, which she did not challenge in court. During the Collection Due Process hearing, the taxpayer failed to provide the requested financial documents or evidence to contest her outstanding tax liabilities. The court granted the Commissioner’s motion for summary judgment, asserting that the IRS did ...