Another case released on May 26, 2016 is TC Memo 2016-105. There's not much great information in the case. However, there is one good point that practitioners should be aware of when helping a client with a Collection Due Process Hearing. If you go to a Collection Due Process Hearing and do not bring up an argument for your client, then you are barred from bringing up that same argument in a Tax Court review of the CDP hearing.
The court really stresses this at the end of TC Memo 2016-105.
Relevant Citations:
TC Memo 2016-105
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