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 held that the IRS abused its discretion by failing to adequately consider a couple’s proposed collection alternative and, citing an undeveloped record, remanded their case so the IRS can determine whether to compromise their tax liability to promote effective tax administration on public policy and equity grounds.

Scott Alan SchumacherJohn Alfred Clynch, Jr., and Emily J. Yamada, for petitioners.

Lisa M. Oshiro, for respondent.

T.C. Memo. 2014-46