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Jurisdiction › Income Taxes › Tax Levy

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

Freeman Law

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

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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 | Cosio v. Commissioner | Collection Due Process and Abuse of Discretion

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Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more

Freeman Law

The Tax Court in Brief - December 2021 #4

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Ahmed v. Comm’r, T.C. Memo. 2021-142 |December 28, 2021 | Thornton, J. | Dkt. No. 12876-18L - Short Summary. The IRS filed a notice of federal tax lien against Mr. Ahmed with respect to his 2013, 2014, 2015, and 2016...more

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