Alan F. Segal & Associates, P.C.

Recent Tax Court Collection Due Process Victory  

[2011-03-08]

On June 21, 2011, the United States Tax Court, in Rosenbloom v. Commissioner, T.C. Memo. 2011-140, sided with the taxpayer and ruled that the Appeals determination to uphold a threatened IRS levy action was an abuse of discretion.  In so doing, the Tax Court invalidated a waiver signed by the taxpayer, extending the statute of limitations on collection and held the taxpayer not liable for more than $600,000.00 in liabilities, plus interest, from the 1980s.  We are pleased to have acted as Counsel for the taxpayer, together with Jon Decatorsmith of the Chicago Kent Low-Income Tax Clinic.   

Areas of Practice

  • Business Taxation
  • Employment Tax and Trust Fund Recovery Penalties
  • Federal Tax Controversies
  • Individual Taxation
  • Innocent Spouse
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