A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.
The United States Tax Court dismissed an individual’s challenge to the IRS’s proposed levy actions for two tax years, finding that the court lacked jurisdiction, and granted the IRS summary judgment regarding a levy for a third tax year, finding that she had failed to respond to the motion and there was no abuse of discretion by the IRS.
JANET MCCULLAR,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent