Collection Due Process Analysis: Abuse of Discretion in Sustaining Levy Regarding Installment Agreements
This article addresses the memorandum opinion in Avalon Home Health, Inc. v. Commissioner, T.C. Memo. 2025-107, a Collection Due Process (CDP) case that provides essential insights into the Internal Revenue Service (IRS) Independent Office of Appeals’ (Appeals) requirement to properly verify statutory requirements and consider collection alternatives under section 6330(c)(3) of the Internal Revenue Code. This case resulted in a partial denial of the Commissioner’s Motion for Summary Judgment and a remand to Appeals due to significant deficiencies in the administrative process.
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