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  • Writer's pictureHolly Roundtree CPA

2019 – 08/27

The 9th U.S. Circuit Court of Appeals has affirmed a U.S. Tax Court decision holding that a husband and wife couldn’t challenge their underlying tax liability at a collection due process (CDP) hearing after they’d reached a settlement with the IRS. The taxpayers had signed Form 870-AD, which documented the settlement agreement. But, they didn’t pay the agreed-on amount. After getting a final notice from the IRS about the tax liability, they requested a CDP hearing. The IRS argued that, when the taxpayers signed Form 870-AD, they waived their statutory right to dispute their tax liability in Tax Court. The Tax Court agreed, and the 9th Circuit affirmed the Tax Court’s ruling. (Potts, 8/19/19)

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