U.S. Tax Court Upholds IRS Levy Action for Collection Due Process Violations

The U.S. Tax Court, in a memorandum decision, upheld the IRS’s determination that the proposed levy collection action was proper because the taxpayer failed to provide the requested financial information and did not properly challenge his underlying tax liabilities during the collection due process hearing. The taxpayer filed tax returns for the years at issue but failed to pay the taxes due, prompting the IRS to send a Notice of Intent to Levy and schedule collection due process hearings. During the hearings, the taxpayer did not provide the requested documentation, including Form 433-A, and continued to argue unsuccessfully about an ...