Law360, Chicago (November 21, 2016, 3:47 PM EST) -- Rejecting tax court precedent, the Seventh Circuit ruled Friday that delinquent taxpayers who weren't properly notified of Internal Revenue Service levies still have to pursue an administrative appeal before they can petition the tax court to invalidate the levy.
Acknowledging the difficulty it presents to taxpayers, the Seventh Circuit nevertheless found tax courts don't have jurisdiction to rule on petitions to invalidate levies unless the taxpayer went to the IRS Office of Appeals first and received a notice of determination.
Without receiving the Final Notice, taxpayers likely wouldn't know about the levy, which allows the IRS to seize property to satisfy...
Stay ahead of the curve
In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.
Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
Create custom alerts for specific article and case topics and so much more!