The collection dispute
Don M. Tellock failed to file income tax returns for 2016 and 2017. In response, the IRS prepared a Substitute for Return (SFR) for each year and issued Notices of Deficiency. Because Tellock did not petition the Tax Court to challenge those notices, he was later barred from disputing the underlying tax liability.
In December 2022, the IRS issued a Final Notice of Intent to Levy for both years, prompting the Tellock to request a collection due process (CDP) hearing with the IRS Independent Office of Appeals. The court’s decision focused solely on the proposed levy for the 2016 tax year since by this time the taxpayer owed no tax for 2017.
To dig deeper, visit the original article on the Thomson Reuters blog.