Case: Proposed Levy Sustained Against Retired Military Officer (T.C. Memo) (IRC §6330)

The IRS did not abuse its discretion in denying Petitioner’s request for collection alternatives relating to his unpaid 2016 tax liability, the U.S. Tax Court held, granting, in part, the government’s motion for summary judgment and sustaining a proposed levy. Petitioner, a retired military officer, filed a 2016 tax return omitting substantial retirement income, including a large lump-sum military retirement distribution. The IRS issued a notice of deficiency, which Petitioner received but did not challenge in the Tax Court. After the IRS assessed the liability and issued a notice of intent to levy, Petitioner requested a collection due process hearing. ...