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Due Process › Internal Revenue Service › Debt Collection

Lippes Mathias LLP

Supreme Court Undermines Taxpayers’ Due Process Rights

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On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more

Rivkin Radler LLP

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

Rivkin Radler LLP on

Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more

McDermott Will & Emery

Tax Court Holds That Deficiency Petition 90-Day Time Limit Is Jurisdictional

McDermott Will & Emery on

Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable tolling (Boechler, P.C. v....more

McDermott Will & Emery

Late CDP Petitions May Still Be Entitled to Tax Court Review

McDermott Will & Emery on

In a unanimous decision in Boechler, P.C. v. Commissioner issued on April 21, 2022, the Supreme Court of the United States reversed the US Court of Appeals for the Eighth Circuit’s ruling (which affirmed the US Tax Court) and...more

Burr & Forman

The IRS is Garnishing My Wages or Taking My Bank Account: What Do I Do? Collection Due Process Relief (Part 9)

Burr & Forman on

If an individual or business owes but has not paid federal taxes, the IRS will make efforts to collect these taxes. The IRS will first send a series of notices requesting payment, but if the taxpayer does not respond to the...more

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