7th Circ. Cuts Appeal Options For IRS Levies

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...

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