Tax court upholds IRS levy after Kansas doctor ignores notices

Foulds v. Commissioner (U.S. Tax Court 2025) Collection Due Process Levy Summary

The Tax Court upheld an IRS levy against a Kansas taxpayer who failed to file returns or respond to deficiency notices, ruling that the IRS properly mailed notices and that Appeals did not abuse its discretion in sustaining collection.

Holding

The Tax Court held that the IRS properly mailed deficiency notices to the taxpayer’s last known address, precludi…