The United States Tax Court Upholds Notice of Federal Tax Lien Filing
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 held that the IRS Appeals Office didn’t abuse its discretion in determining to sustain a notice of federal tax lien filing against an individual, finding that Petitioner couldn’t challenge most of his underlying tax liabilities, he didn’t properly raise other issues during his hearing, and he didn’t show that overpayments of tax weren’t properly applied.
WALTER THORWALD SKALLERUP 3RD,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent