Ex-CPA Claims IRS Ignored Evidence in Bid to Revive Tax Offset

An ex-accountant and his wife have “ample substantiation” of net operating losses that the IRS allegedly ignored in order to proceed with a levy on their home, the couple told a federal appeals court.

Allen and Sharon Davison challenged the Tax Court’s decision to sustain the IRS’s notice of intent to levy. The court said the IRS had given the couple due consideration of their NOL carryback claims before disallowing them, and the Davisons’ failure to present records was fatal to their relief claim. The Davisons on Monday asked the US Court of Appeals for the Tenth Circuit to find ...