Corporation Suspended By State of California Unable to Challenge IRS Collection Determination in Tax Court
No longer possessing a valid charter can create a situation where the entity is unable to file in Tax Court to dispute an IRS finding. That was the situation for the corporation in the case of Urgent Care Registries, Inc. v. Commissioner, TC Memo 2016-198.
The corporation in this case had filed some income and employment tax returns for 2009 through 2013 but enclosed no payments. As well, some returns that it should have filed were never filed and the IRS prepared substitutes for returns (SFR). The IRS assessed the taxes and penalties, and send the taxpayer a Final Notice of Intent to Levy.
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