Jurisdiction, Internal Revenue Code (IRC), Tax Liability

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

Senators Crapo and Wyden Release Draft Bipartisan Taxpayer Rights Legislation

Proskauer - Tax Talks on 3/3/2025

On January 30, 2025, Mike Crapo (R-ID), the Chairman of the Senate Finance Committee, and Senator Ron Wyden (D-OR), the Ranking Member of the Senate Finance Committee released a discussion draft of the “Taxpayer Assistance...more

Tax Court in Brief | XC Foundation v. Comm’r | Tax Court Jurisdiction and Corporate Capacity to Seek Relief

Freeman Law on 1/10/2023

Summary: XC Foundation (“XC”) was incorporated in California in 2007. In 2008, the IRS issued XC a determination letter recognizing it as exempt from federal income tax under section 501(c)(3) and as a private foundation...more

A Win for Taxpayers—Section 6330(d)(1) is a Nonjurisdictional Deadline

Freeman Law on 5/3/2022

Collection Due Process Hearings and Jurisdiction Collection Due Process (“CDP”) hearings are crucial to taxpayers. Taxpayers have a right to a Collection Due Process hearing with the IRS Independent Office of Appeals before...more

The Tax Court in Brief - December 2021 #4

Freeman Law on 1/21/2022

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

The Tax Court in Brief - December 2021

Freeman Law on 1/7/2022

Tax Litigation: The Week of December 6 – December 10, 2021 - Coggin v. Comm’r, 157 T.C. No. 12 | December 8, 2021 | Weiler, J. | Dkt. No. 21580-19 - Short Summary: Alice J. Coggin (“Coggin”), who was married during...more

Recent Bankruptcy Court Ruling Addresses the Jurisdiction of Bankruptcy Courts to Hear Innocent Spouse Relief Cases

Freeman Law on 8/12/2021

The recent case of In re Bowman, Case No. 20-11512, Section A (Bankr. E.D. La., July 12, 2021) addresses an interesting intersection of tax and bankruptcy law. Specifically, it looks at the issue of whether bankruptcy courts...more

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