On August 31, 2021, the Tax Court issued a Memorandum Opinion in the case of Webb v. Commissioner (T.C. Memo. 2021-105). The primary issue presented in Webb v. Commissioner was whether Appeals abused its discretion when it declined to place the petitioner in currently not collectible (CNC) status. Background to Webb v. Commissioner On March 4, 2019, the IRS issued to the petitioner a Notice of Intent to Levy and Notice of Your Right to a Hearing (CDP levy notice) advising her that the IRS intended to levy to collect her outstanding tax for the tax year 2017. The petitioner’s representative timely requested a collection due process (CDP) hearing in response to the CDP levy notice, in which the petitioner sought to be placed in CNC status. The petitioner’s representative submitted a completed Form 433-A (Collection Information Statement for Wage Earners and Self-Employed Individuals), and copies of bank statements, pay stubs,…