U.S. Tax Court Memorandum Decision Upholds IRS Certification of Seriously Delinquent Tax Debt for Taxpayer

The U.S. Tax Court, in a memorandum decision, found that the certification of a taxpayer as owing a seriously delinquent tax debt was not erroneous, granting summary judgment for the IRS. Taxpayer, a medical doctor who owned several businesses, was assessed trust fund recovery penalties (TFRPs) for unpaid employment taxes. The IRS certified the taxpayer’s debt as seriously delinquent under IRC §7345 after assessing the TFRPs, filing a notice of federal tax lien, and issuing a levy. The taxpayer challenged the certification in Tax Court. The court held that the certification was proper because the taxpayer’s unpaid, assessed TFRP liabilities ...