No IRS Abuse of Discretion by IRS Appeals Office and Couple Penalized for Frivolous Arguments in Collection Challenge
The United States Tax Court upheld the IRS’s determination to sustain a notice of federal tax lien filing against a couple and imposed a $3,500 penalty against them for advancing frivolous arguments, finding that the IRS’s decision to sustain its proposed collection action was proper as a matter of law. Summary Judgment granted.
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.
GEORGE H. PATTON AND FELOMINA F. PATTON,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent