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

Expiration of Statute of Limitations Period Prevents IRS Collection of Tax Debt

The United States Tax Court held that the IRS can’t collect an individual’s unpaid taxes because the statute of limitations for collection expired, finding that the IRS, which conceded that the account transcript was inaccurate, failed to establish that an installment agreement was entered along with a waiver to extend the limitations period.

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.

PAUL W. GRAUER,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2016-52