U.S. Tax Court Remands Collection Due Process Case for Verification Failures

The U.S. Tax Court held that Taxpayer was not liable for the full amount of collection actions because Appeals failed to properly verify assessments and consider collection alternatives. Taxpayer, an individual business owner, filed income tax returns for tax years 2011 through 2017 and was subsequently audited, resulting in deficiencies, additions to tax, and penalties. Taxpayer claimed identity theft issues and disputed the examination results, arguing that the IRS failed to consider his business expenses and that the assessed amounts were erroneous. The IRS issued notices of intent to levy and filed notices of federal tax lien, prompting Taxpayer to ...