On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Norberg v. Commissioner (T.C. Memo. 2022-30). The primary issue presented in Norberg v. Commissioner was whether the settlement officer abused its discretion in upholding a notice of intent to levy and denying the petitioners’ request to be placed in currently not collectible status (despite having the ability to make payments). Held:  Background to Norberg v. Commissioner In February 2019, the