Challenging Levy Archives | Briefly Taxing

Challenging Levy

Kazmi v. Commissioner
T.C. Memo. 2022-13

On March 1, 2022, the Tax Court issued a Memorandum Opinion in the case of Kazmi v. Commissioner (T.C. Memo. 2022-13). The primary issues presented in Kazmi v. Commissioner were (1) whether the petitioner is entitled to challenge the underlying liabilities, and if so, whether he is a responsible person who willfully failed to pay over employment taxes under IRC § 6672, and (2) whether the Appeals abused its discretion in sustaining the collection action.

Scott St. Amand May 20, 2022

Challenging Levy

Reynolds v. Commissioner
T.C. Memo. 2021-10

On January 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Reynolds v. Commissioner (T.C. Memo. 2021-10). The issue presented in Reynolds v. Commissioner was whether the IRS possessed the collection authority under IRC § 6201(a)(4) to undertake administrative collection action to collect restitution-based assessments (RBAs). Note on “Precedent” to Reynolds v. Commissioner It should be noted that the argument the petitioner made in Reynolds was “squarely rejected” in the case

Scott St. Amand January 26, 2021

Challenging Levy

Strashny v. Commissioner
T.C. Memo. 2020-82

On June 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Strashny v. Commissioner (T.C. Memo. 2020-82). The issue before the court in Strashny v. Commissioner was whether Appeals abused its discretion in sustaining the proposed collection action. Background to Strashny v. Commissioner The petitioners timely filed their 2014 Form 1040 but did not pay the tax shown as due. The IRS assessed the tax and an addition to tax for

Scott St. Amand June 11, 2020

Al Capone

Onyeani v. Commissioner
T.C. Memo. 2020-15

On January 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Onyeani v. Commissioner (T.C. Memo. 2020-15). The issue presented in Onyeani v. Commissioner was whether the IRS appropriately issued a termination assessment against the petitioner and determined that his illegal income was taxable. Note on Onyeani v. Commissioner Hello, dear reader, I am Ogorji Timothy Wilson Onyeani, a Nigerian doctor, who has come upon a sum of money in the

Scott St. Amand January 16, 2020