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Tax Court Lacks Jurisdiction on $80,000 Compromise Payment Refund

Jan. 24, 2023, 8:49 PM

A ruling from the US Tax Court finding that it didn’t have jurisdiction to order the IRS to refund the initial payment of a tax repayment offer was affirmed by the Ninth Circuit.

Michael Brown owes $50 million on unpaid taxes between 2001 and 2011. Brown sought a refund of $80,000 that he paid to the IRS as a Tax Increase Prevention and Reconciliation Act payment—a 20% payment included with the lump sum amount made as an offer to the IRS toward paying down tax debts under tax code Section 7122(c).

The IRS returned the ...