Tax Levy, Income Taxes, Tax Court

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

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

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 Levy › Income Taxes › Tax Court

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

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

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

Tax Court in Brief | Lipka v. Comm’r | Collection Alternatives, Economic Hardship, and Abuse of Discretion

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

Tax Court in Brief | Bunton v. Comm’r | Collection Due Process and “Last Known Address

Tax Court in Brief | Cosio v. Commissioner | Collection Due Process and Abuse of Discretion

The Tax Court in Brief - December 2021 #4

Tax Levy › Income Taxes › Tax Court

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