U.S. Appeals Court Affirms IRS Collection Actions, Cites Taxpayer Fails to Challenge Tax Court Ruling

The U.S. Court of Appeals for the Third Circuit affirmed the Tax Court’s decision to sustain IRS collection actions against the taxpayer. Taxpayer, an individual, had unpaid income tax and penalties for tax years 2009 and 2012, as well as a civil penalty for filing a frivolous return in 2017. The IRS proposed a levy and federal tax lien to collect these amounts. The taxpayer petitioned the Tax Court to challenge the Notice of Determination, sustaining these collection actions. The Tax Court granted summary judgment for the IRS regarding the collection actions and dismissed the taxpayer’s remaining claims for lack ...