Foreign Reporting Penalty Targets Claim IRS Skipped Due Process

A couple fighting penalties for their alleged failure to disclose foreign financial accounts to the Treasury Department asked the Eleventh Circuit to revive their due process lawsuit, arguing the US Tax Court has jurisdiction to hear it.

Stephen and Judy Jenner sued the IRS for denying them a collection due process (CDP) hearing—a setting where taxpayers can dispute their liabilities or discuss payment alternatives. The couple said they had no prior chance to contest how much they owed before the agency began levying their Social Security benefits.

The Tax Court dismissed that lawsuit last month, ruling the civil penalties in ...