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, finding no abuse of discretion by the IRS in sustaining a proposed levy, held that an individual deliberately failed to claim a certified letter informing him of the proposed assessment of trust fund recovery penalties against him and, thus, couldn’t challenge the liability in his collection due process hearing.
CESARE GIAQUINTO, Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent