U.S. Tax Court Decides Miccosukee Tribe v. Commissioner



An excerpt:

The Internal Revenue Service (IRS) Appeals Office sent petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) with respect to notices of Federal tax lien (NFTLs) and a notice of intent to levy filed to collect petitioner’s unpaid tax liabilities for tax years ended December 31, 2000 through 2005. The sole issue for decision is whether the Appeals Office abused its discretion by sustaining the lien and levy actions for these years. We hold that it did not.