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 a settlement officer didn’t abuse her discretion by making a determination to sustain IRS lien and levy actions against a couple for unpaid tax liabilities, finding that the couple, who didn’t respond to the IRS’s motion for summary judgment, failed to show the existence of any material facts in dispute.

ROBERT TRIOLA AND NANCY V. TRIOLA,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-166