Case: U.S. Tax Court Upholds IRS’ Rejection of Taxpayers’ Installment Agreement (T.C. Memo)

The U.S. Tax Court held that the IRS did not abuse its discretion in sustaining notices of federal tax lien filings against the taxpayers for unpaid tax liabilities, granting summary judgment for the IRS. The taxpayers, a married couple, had unpaid federal income tax liabilities for multiple tax years. At the collection due process hearing, the taxpayers proposed an installment agreement (IA), which the Settlement Officer (SO) rejected based on an analysis showing the taxpayers could pay more per month or pay the full liability from available assets. Upon review of the taxpayer’s appeal, the Tax Court held that the ...