2019- 10/18 A taxpayer, a swimming pool builder, failed to pay its employment taxes for several quarters. The IRS filed a Notice of Federal Tax Lien against it. At a Collection Due Process hearing, the taxpayer requested an installment agreement as a collection alternative. The IRS Appeals Officer (AO) asked for proof that the company was making the mandatory payroll tax deposits. But the taxpayer failed to provide a signed copy of the payroll tax return or proof of the deposits. Therefore, the AO rejected the taxpayer’s proposed installment agreement and sustained the filing of the lien notice. The U.S. Tax Court agreed, finding no “abuse of discretion” on the AO’s behalf. (TC Memo 2018-130)

Similar Posts