The United States Tax Court Upheld a Levy Against Charitable Foundation to Collect Penalty
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 IRS appeals officer didn’t abuse his discretion when he sustained a proposed levy against a nonexempt charitable trust treated as a foundation to collect penalties assessed against the foundation for failing to timely file a return, finding that proper administrative and statutory procedures were followed.
GRACE FOUNDATION, R. S. OHENDALSKI, TRUSTEE,
COMMISSIONER OF INTERNAL REVENUE,