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 StatesTax Court, imposing a frivolous argument penalty, found no abuse of discretion by the IRS in sustaining a levy against a couple and held that the IRS satisfied its obligation to provide them with records of assessment; the couple’s attorney must show cause why he shouldn’t be required to pay excessive costs to the IRS under section 6673(a)(2).
LEONARD L. BEST AND EVELYN R. BEST,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent