IRS can proceed with levy after rejecting inspection agency’s $250,000 settlement offer

Middle Dep't Inspection Agency, Inc. v. Commissioner, T.C. Memo. 2025-99, No. 20018-23L., 2025 BL 351926, Court Opinion

On October 1, 2025, the U.S. Tax Court upheld the IRS’s decision to reject Middle Department Inspection Agency, Inc.’s (MDIA) $250,000 offer to settle over $9 million in excise tax liabilities.

The court ruled that the IRS Independent Office of Appeals did not abuse its discretion when it denied MDIA’s offer and sustained a proposed levy to collect unpa…