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Internal Revenue Service › Due Process › Tax Liability

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.  
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

Hone Maxwell

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

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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

Rivkin Radler LLP

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

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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

Miller Canfield

Watch the Scope of Your IRS Closing Agreement

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The rules relating to delegated authority are complex. A taxpayer is well advised to ensure that the scope of a closing agreement the taxpayer signs is what the taxpayer expects, and that an IRS official who signs the...more

Freeman Law

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

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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

Freeman Law

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

Freeman Law on

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

Freeman Law

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

Freeman Law on

Tax Litigation:  The Week of May 9th, 2022, through May 13th, 2022 Lewis v. Commissioner, TC Memo. 2022-47| May 9, 2022 | Greaves, J. | Dkt. No. 10007-20W Rogerson v. Commissioner, TC Memo. 2022-49| May 12, 2022 | Toro, J. |...more

Freeman Law

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

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Tax Litigation: The Week of March 28, 2022, through April 1, 2022 Addis v. Comm’r, T.C. Memo. 2022-24 | March 28, 2022 |Urda, J. | Dkt. No. 12140-20L Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt....more

Freeman Law

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

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Tax Litigation:  The Week of March 28, 2022, through April 1, 2022 Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt. No. 3544-21 Golditch v. Comm’r, T.C. Memo. 2022-26 | March 29, 2022 |Lauber, J. |...more

Freeman Law

Tax Court in Brief | Shaddix v. Commissioner | Collections Due Process Hearings and Liability

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Tax Litigation: The Week of February 28, 2022, through March 4, 2022 - Estate of Kazmi v. Comm’r, T.C. Memo. 2022-13| March 1, 2022 | Paris, E. | Dkt. No. 5013-18L - Estate of Levine v. Comm’r, 158 T.C. No. 2 | February 28,...more

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