No IRS Abuse of Discretion when Installment Agreement Does Not Preclude Notice of Federal Tax Lien Filing
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, held that the IRS did not abuse its discretion in a determination sustaining a notice of federal tax lien filing against a couple who had an installment agreement, but who had defaulted on prior agreements; the court also held that equitable estoppel should not be applied against the IRS to stop the lien filing.
KENNETH JOHN MELIKIAN AND SHARON KAYE MELIKIAN,
COMMISSIONER OF INTERNAL REVENUE,