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Do you remember the story of Konstantin and Nadezhda Anikeev? The couple caught the limelight in 2021 when the IRS contented them for owing taxes of more than…
Llanos v. Commissioner | February 22, 2021 | Kerrigan, K. | Dkt. No. 8424-19L
Short Summary
: IRS assessed § 6702 penalties against petitioner for filing frivolous returns. Eventually the IRS issued a Final Notice of Intent to Levy, to which the taxpayer timely request a CDP hearing. At the CDP hearing, the petitioner indicated that he had not received the required notices of deficiency for the civil penalties. Petitioner did not request any collection alternatives. The settlement officer upheld the levy action, and petitioner filed in tax court. Tax court held for the IRS.
Key Issue: Whether petitioner made a “meaningful” challenge to the penalties so as to trigger a de novo review, and whether the levy action was appropriate.
Feb 24, 2021
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Correction 2/25/21: This article has been updated to reflect that Visa gift card purchases are considered products by the court, while prepaid debit card reloads and money order purchases are not.
This month, the U.S. Tax Court ruled that in some cases credit card rewards can be subject to taxation by the Internal Revenue Service (IRS).