The Statute of Limitations Period Bars IRS’s Lien Collection Efforts
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 an Appeals Office IRS settlement officer improperly sustained a notice of federal tax lien to recover a trust fund recovery penalty against an individual, finding that collection was barred because the 10-year limitations period in Code section 6502 had expired and was not tolled by the individual taxpayer’s frequent trips outside the United States.
KIM REINHART,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent.