The U.S. Tax Court held that taxpayers were precluded from challenging their underlying tax liabilities for section 6707 penalties in a collection due process (CDP) hearing. The taxpayers had received ...

At a time when questions may arise regarding your rights it could be comforting to know that, at least as to the US Internal Revenue Service, there is a clear statement of general rights as an ...

The Supreme Court on Thursday held that the Tax Court lacked jurisdiction over a taxpayer’s collection due process (CDP) appeal of a proposed tax levy once the underlying tax liability was satisfied, ...