IRS, Tax Debt, Tax Court

Supreme Court Undermines Taxpayers’ Due Process Rights

Lippes Mathias LLP on 6/30/2025

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

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

Rivkin Radler LLP on 10/31/2024

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

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

Rivkin Radler LLP on 4/19/2024

Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

IRS Levy Allowed on Classic Italian Cello to Satisfy Outstanding Estate Tax Liabilities

Lerch, Early & Brewer on 10/9/2023

United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more

Self-Employment Tax and the Limited Partner – Substance Over Form, or Something Else?

Rivkin Radler LLP on 9/14/2023

Last week, the IRS announced “the start of a sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promoters abusing the...more

Move Over TikTok, the Tax Man May Be Snooping on You, Too

Kohrman Jackson & Krantz LLP on 6/2/2023

In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more

Tax Court in Brief | Belton v. Comm'r | Seriously Delinquent Tax Debt” and IRS Requirement to Comply with Lien Procedure

Freeman Law on 1/30/2023

Summary: Petitioners, Willard Belton and Martha-Alexander Belton (Petitioners or Beltons) seeks review pursuant to section 7345(e), challenging the IRS’s certification to the Secretary of State that Petitioners had a...more

Tax Court in Brief | Adams v. Comm’r | “Seriously Delinquent Tax Debt” and Passport Revocation

Freeman Law on 1/30/2023

Summary: Petitioner, Blake M. Adams, seeks review pursuant to section 7345(e) of the IRS’s certification to the Secretary of State that Adams has a “seriously delinquent tax debt” related to tax years 2007, 2009, 2010, 2011,...more

Tax Court in Brief | Mattson v. Comm’r | Passport Revocation Notice for “Seriously Delinquent Tax Debt”; Limitations on Tax Liens

Freeman Law on 12/9/2022

Tax Litigation: The Week of December 5th, 2022, through December 9th, 2022 - Mattson v. Comm’r, T.C. Memo. 2022-118 | December 6, 2022 |Copeland, J. |Docket No. 16982-18P - Summary: Eric Mattson did not file income tax...more

Internal Revenue Service › Tax Debt › Tax Court

Supreme Court Undermines Taxpayers’ Due Process Rights

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

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

IRS Levy Allowed on Classic Italian Cello to Satisfy Outstanding Estate Tax Liabilities

Self-Employment Tax and the Limited Partner – Substance Over Form, or Something Else?

Move Over TikTok, the Tax Man May Be Snooping on You, Too

Tax Court in Brief | Belton v. Comm'r | Seriously Delinquent Tax Debt” and IRS Requirement to Comply with Lien Procedure

Tax Court in Brief | Adams v. Comm’r | “Seriously Delinquent Tax Debt” and Passport Revocation

Tax Court in Brief | Mattson v. Comm’r | Passport Revocation Notice for “Seriously Delinquent Tax Debt”; Limitations on Tax Liens

Tax Court in Brief | Goddard v. Comm'r | Collection Due Process, Penalties for Failure to Register a Tax Shelter

Tax Court in Brief | Kotrides v. Commissioner | Collection Due Process, Abuse of Discretion, and Summary Judgment

Tax Court in Brief | Ezekwo v. Commissioner | Passport Revocation for Seriously Delinquent Tax Debt

Should Your Lawyer Be a Grammar Nerd?

[Webinar] Freeman Law Legal and Tax Update - March 30th, 1:00 pm CT

Internal Revenue Service › Tax Debt › Tax Court

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