Case: Tax Court’s Review of IRS Certifications of Seriously Delinquent Tax Debt is De Novo, Summary Judgment Denied (T.C.) (IRC §7345)

The Tax Court’s review of IRS certifications of seriously delinquent tax debt under I.R.C. §7345 is de novo; it is not limited to the administrative record and may include evidence introduced at trial, the U.S. Tax Court held, deciding an issue of first impression and denying the IRS’s motion for summary judgment. Taxpayer, an individual, had unpaid tax liabilities which the IRS assessed between 2007-2010, reduced to judgment in a district court in 2014, and certified as a seriously delinquent tax debt in 2022. Taxpayer challenged the IRS’s certification, arguing he was never served in the district court action that ...