A couple fighting penalties for their alleged failure to report foreign financial holdings told a federal appeals court that they are entitled to a due process review before the government levies their Social Security benefits.
Stephen and Judy Jenner asked the US Court of Appeals for the Eleventh Circuit on Thursday to revive their collection due process case, arguing that its dismissal deprived them of the chance to contest their underlying liability before the government’s levy.
The US Tax Court tossed the Jenners’ case, saying their civil penalties weren’t taxes and therefore weren’t subject to levy review procedures under ...