Case: U.S. Tax Court Upholds IRS Decision on Tax Lien, Levy Against Taxpayers (T.C. Memo)

The U.S. Tax Court held that the IRS did not abuse its discretion in sustaining a tax lien and proposed levy against the Taxpayers, affirming the IRS determination. Taxpayers, a married couple, owed over $146,000 in unpaid income taxes for multiple tax years. They requested an installment agreement during their Collection Due Process hearing. The Appeals Officer verified proper procedures were followed, considered the Taxpayers’ request for an installment agreement, and balanced efficient tax collection with the Taxpayers’ concerns. The court held there was no abuse of discretion because: (1) the Appeals Officer properly followed IRS guidelines in requesting that ...