Tax Levy, Due Process, IRS

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

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

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

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 | Addis v. Commissioner | Collection Due Process and Frivolous Positions

Freeman Law on 4/5/2022

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

Burr & Forman on 9/27/2017

If an individual or business owes but has not paid federal taxes, the IRS will make efforts to collect these taxes. The IRS will first send a series of notices requesting payment, but if the taxpayer does not respond to the...more