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

The United States Tax Court Upholds Deficiency, Notice of Federal Tax Lien and No IRS Abuse of Discretion Found

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, in a summary opinion, affirmed an assessment of income tax deficiency and sustained a notice of federal tax lien because the Tax Court found no abuse of discretion by the IRS, noting that the taxpayer had a prior opportunity to contest his tax liability but neglected to do so.

BRIAN CRAIG JOHNSON,

Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Summ. Op. 2014-90