The client came to our Office with a tax liability already in collections. The clients timely filed a Collection Due Process request in response to a notice of intent to levy, requesting a suitable installment agreement. The IRS agent denied our clients’ request for an installment agreement and issued a Notice of Determination sustaining the IRS’s intent to levy. Our office petitioned the U.S. Tax Court in response to a Notice of Determination arguing improper review of our clients’ installment agreement requests amongst other deficiencies. After the IRS answered the petition, our office filed a Motion to Remand with the Court requesting the Court send the case back to appeals to review, arguing Appeals abused its discretion in coming to its determination. It is difficult for taxpayers to win on these motions, but after oral argument, the Court, citing IRS appeals agent’s improper review, remanded the case back to Appeals so the clients can have its case heard again by the IRS agent. You can see the Court’s opinion here: https://www.taxnotes.com/research/federal/court-documents/court-opinions-and-orders/collection-case-remanded-appeals-consider-ability-pay/7l5df
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