United States Tax Court Decision for the Week – You be the Judge

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 remanded to IRS Appeals for further consideration a case in which an appeals officer made an erroneous determination in favor of a taxpayer who failed to participate in proceedings against her, rejecting the IRS’s request to find the officer abused his discretion and declining to invalidate the IRS’s supplemental notice and uphold its notice of federal tax liens for six tax years.

JUDY MACDONALD,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-42

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