Tax Coda

Tax Coda

Tax court upholds levy after business fails to support installment proposal

DCSL, LLC v. Commissioner, No. 11416-24SL., T.C. Summary Opinion 2025-9, 2025 BL 386099, Court Opinion

Tax Coda's avatar
Tax Coda
Nov 03, 2025
∙ Paid

The Tax Court upheld the IRS’s decision to proceed with a levy after the taxpayer failed to provide the required financial information to support its proposed installment agreement.

Holding

The Tax Court granted summary judgment for the IRS, finding no abuse of discretion in sustaining a levy against DCSL, LLC, for unpaid payroll tax liabilities. The taxp…

User's avatar

Continue reading this post for free, courtesy of Tax Coda.

Or purchase a paid subscription.
© 2026 Tax Coda · Publisher Terms
Substack · Privacy ∙ Terms ∙ Collection notice
Start your SubstackGet the app
Substack is the home for great culture