Family’s Personal Spending Justifies Early Tax Collection Effort

The IRS properly issued an almost $15 million jeopardy assessment against an estate and its executor when he refused to pay the taxes agreed to by his deceased father, a federal court said.

The US can initiate jeopardy assessments when it believes waiting for US Tax Court litigation to resolve would impair its ability to ultimately collect the tax—usually when a taxpayer appears to be preparing to leave the country, conceal themselves, or shield their assets. Under such conditions, 26 U.S.C. § 6861 authorizes the agency to begin collection efforts before Tax Court proceedings resolve.

The jeopardy assessment against Gunter ...