News & Analysis as of August 18, 2025

Income Taxes

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The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.

Supreme Court Gives IRS Ability to Levy Taxpayers Without Tax Court Challenge

Hone Maxwell on 6/26/2025

In a pivotal ruling, the U.S. Supreme Court on June 12, 2025, held that the U.S. Tax Court lacks jurisdiction to hear a taxpayer’s Collection Due Process appeal under IRC § 6330 once the IRS can no longer pursue a levy,...more

Mailing Your Tax Return by the Due Date Is Not Enough

McGlinchey Stafford on 10/3/2023

A recent United States Tax Court memorandum decision demonstrates once again the importance of understanding the rules for timely filing your tax return. See John P. Zaimes v. Commissioner of Internal Revenue. If a tax return...more

Tax Court in Brief | Avery v. Comm’r | Collection Due Process and a Lawyer’s Race Car Business Expense Deductions

Freeman Law on 2/27/2023

Summary: Since 1982, James William Avery (Avery) was a practicing lawyer, specializing in personal injury law as a solo practitioner primarily in Denver, Colorado for the period 2008–2013 but also some in Indiana during...more

Tax Court in Brief | Schwartz v. Comm’r | Collection Due Process; Credit Election Overpayment; Quintessential Tax Procedure

Freeman Law on 12/27/2022

Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary: Eric Schwartz (“Schwartz”) and his spouse divorced. Pursuant to those divorce proceedings, the state court...more

Tax Court in Brief | Jackson v. Commissioner | What’s at Issue in Reviewing the Determination of a Collection Due Process Hearing?

Freeman Law on 5/26/2022

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Internal Revenue Service › Due Process › Income Taxes

Supreme Court Gives IRS Ability to Levy Taxpayers Without Tax Court Challenge

Mailing Your Tax Return by the Due Date Is Not Enough

Tax Court in Brief | Avery v. Comm’r | Collection Due Process and a Lawyer’s Race Car Business Expense Deductions

Tax Court in Brief | Schwartz v. Comm’r | Collection Due Process; Credit Election Overpayment; Quintessential Tax Procedure

Tax Court in Brief | Jackson v. Commissioner | What’s at Issue in Reviewing the Determination of a Collection Due Process Hearing?

Tax Court in Brief | Golditch v. Commissioner | Collection Due Process and Frivolous Arguments

Tax Court in Brief | Addis v. Commissioner | Collection Due Process and Frivolous Positions

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

Internal Revenue Service › Due Process › Income Taxes

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