Lawyer’s Failure to File Tax Returns Sinks Appeal for Compromise

The IRS Office of Appeals rightly sustained a proposed levy against a tax-delinquent attorney because his failure to file returns made him ineligible for collection alternatives, the Third Circuit said Thursday.

John A. Hartmann, who represented himself, had appealed the US Tax Court’s judgment finding the IRS hadn’t abused its discretion when rejecting his proposed alternatives to the levy, which included an installment agreement, an offer in compromise, or a finding that he couldn’t pay his balance. The US Court of Appeals for the Third Circuit agreed with the Tax Court that Hartmann hadn’t provided the necessary documentation to prove ...