Taxpayers’ Challenge to IRS Procedure, Tax Court Judges Fails

A couple challenging the IRS’s efforts to collect some $2 million in back taxes and penalties failed to convince a federal appeals court that the agency acted illegally.

In an unpublished decision Tuesday, the US Court of Appeals for the Eleventh Circuit rejected Stanley and Zmira Battat’s argument that the IRS violated IRC Secton 6751(b)(1) by failing to obtain written approval when issuing the levy.

The Eleventh Circuit’s 2022 opinion in Kroner v. Commissioner, which reversed a Tax Court’ ruling that Section 6751 requires a supervisor’s approval to impose penalties, the court said in its unsigned opinion.

Kroner found ...