Mason v. Commissioner T.C. Memo. 2021-64
On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Mason v. Commissioner (T.C. Memo. 2021-64). The primary issue presented in Mason v. Commissioner was whether Appeals abused its discretion by reviewing the Centralized Unit's decision for abuse of discretion instead of reviewing the Masons’ offer on its merits. Background to Mason v. Commissioner: A Lesson in Bureaucracy Victor and Katherine Mason owed back taxes. They didn't deny it, but they said they didn't have the money to pay. They submitted an offer to compromise the debt, and the IRS routed it to the part of the bureaucracy--the Centralized Offer-In-Compromise Unit--that reviews these offers. But another part of the IRS began sending collection notices to the Masons. The Masons asked for a hearing with the IRS Appeals Office. IRS Appeals is supposed to consider alternatives to forced collection at these hearings, including offers like the…