Case: Tax Court Upholds Unpaid Payroll Tax Levy on Taxpayer, Rejects Proposed Installment Plan

The US Tax Court issued a decision upholding an IRS levy notice against taxpayer for failure to timely pay tax owed. Taxpayer had unpaid payroll tax liabilities for several quarters in 2022. After receiving a notice of intent to levy, taxpayer requested a hearing and proposed an installment agreement of $2,500 per month. The Appeals Officer rejected this proposal and offered an agreement of $4,200 per month, based on the assumption that taxpayer’s sole owner could lend funds to the business by accessing equity in personal assets. The officer gave taxpayer time to address this assumption and provide documentation refuting ...