No IRS Abuse of Discretion Affirms Tax Court Holding

A Tax Court decision was affirmed dealing with  IRS Abuse of Discretion. J. Frank Best, Tax Controversy CPA/U. S. Tax Court Litigator with locations in Raleigh and Wilmington, NC  & North Myrtle Beach and Myrtle Beach, SC works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for clients.

IRS Mailed Deficiency Notice to Taxpayer’s Last Known Address: In Williams v. Comm’r, 2019PTC 464 (5th Cir. 2019), the Fifth Circuit affirmed a Tax Court holding regarding IRS Abuse of Discretion that an IRS deficiency notice had been mailed to the last known address of a self-employed taxpayer who had failed to file tax returns for 10 years. The court also rejected the taxpayer’s argument that he was denied constitutionally effective due process of law after the court found that the IRS provided the statutorily required collection due process hearing and the taxpayer declined to avail himself of the opportunity to challenge the deficiency.

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