U.S. Tax Court Memorandum Decision Upholds IRS’s Penalty Award, Validates Installment Agreement Resolution

The U.S. Tax Court upheld the IRS’s decision regarding a taxpayer’s penalties and interest, affirming that the IRS acted within its discretion by resolving the case through an installment agreement. The taxpayer had filed inaccurate tax returns, leading to deficiencies and penalties. After receiving a notice of intent to levy, the taxpayer requested a Collection Due Process hearing, but had previously missed the chance to contest the penalties. Although he could have challenged the interest and failure-to-pay additions, he did not provide evidence for abatement. By agreeing to the installment agreement, the taxpayer avoided the proposed levy. [Salazar v. Commissioner, ...