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 Tax Court, in a collection due process case, granted summary judgment in favor of the IRS, finding that it had properly sustained a levy because the taxpayer did not provide any documentation before his CDP hearing, did not attend the hearing or ask for it to be rescheduled, and did not respond to the IRS’s “last chance” letter.
FRANK GIBSON,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent