High Court Blocks Trust From Disputing IRS Levy

Law360, New York (April 30, 2007, 12:00 AM EDT) -- A trust has lost its attempt to challenge the Internal Revenue Service’s levies upon a third party that was receiving funds from the trust.

The Supreme Court ruled Monday in a unanimous decision that because the trust missed a statutory filing deadline, the trust could not dispute the levy through an action for a tax refund.

In this case, Elmer and Dorothy Cullers established the EC Term of Years Trust in 1991. The IRS, in September 1999, charged a bank account in which the trust had...
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