Case: U.S. District Court Upholds IRS’s Right to Foreclose on Property for Unpaid Taxes, Invalidates Spouse’s Trust Transfer

The U.S. District Court held that the IRS was entitled to reduce federal tax assessments against the taxpayer to judgment and foreclose federal tax liens on a residential property. The taxpayer, an individual, had not filed federal income tax returns since 2002 despite earning income above the filing threshold. The IRS assessed unpaid taxes and penalties against the taxpayer for tax years 2014-2017 based on a bank deposit analysis. The court held that the IRS met its initial burden by presenting Form 4340s and other evidence supporting the assessments, which the taxpayer failed to rebut. Regarding the property, the court ...