The United States Tax Court finds no IRS Abuse of Discretion by Denying “Currently not Collectible” and other Collection Alternatives and Sustains the Filing of Federal Tax Lien Against an Individual
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 Appeals Office didn’t abuse its discretion in denying an individual “currently not collectible” status and other collection alternatives presented, or in sustaining the filing of a notice of federal tax lien and proposed levy action against the individual, who failed to file delinquent income tax returns and provide requested financial documents.
BRIAN R. CUNNINGHAM,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent