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 held that the IRS didn’t abuse its discretion in sustaining a proposed levy against an individual who was given an opportunity for a face-to-face hearing to dispute the underlying liability, provided no evidence that the liability was incorrect, and proposed no collection alternatives.
MICHAEL R. GENTILE,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
T.C. Memo. 2013-175