On November 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Roberts v. Commissioner (T.C. Memo. 2021-131). The primary issue presented in Roberts was whether the settlement officer abused his discretion in determining that petitioner was ineligible for a collection alternative. Held: No. Background to Roberts v. Commissioner The petitioner has unpaid tax liabilities for 2004-2007. In an effort to collect these liabilities the IRS filed an NFTL, and in May