Collection Due Process hearings

Taxpayers that dispute a past-due tax bill can request a Collection Due Process (CDP) hearing, but they must follow all procedures. One married couple failed to file a 2016 federal return. The IRS used third-party reports to determine the couple had taxable income of $112,107 and a tax bill of $30,491. The couple then filed a late tax return but paid no taxes, so the IRS notified them that their assets were subject to seizure. After they requested a CDP hearing and an installment payment plan, the IRS offered the couple a monthly payment plan, but they didn’t respond. The U.S. Tax Court ruled the IRS properly handled the case and could proceed with collection activity. (TC Memo 2023-48)

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