Daily Tax Report ®

Case: Certiorari Writ to Supreme Court Considered ‘Appeal’ to Toll Collection Statute (E.D. Pa.) (IRC §6330)

May 22, 2020, 5:00 AM

Government action to collect taxes timely filed as a taxpayer’s petition to the Supreme Court considered an appeal that tolled the 10-year collection window, a district court held. Taxpayer has not paid his taxes for 1986 through 1991 because of bankruptcy filings and legal challenges in other forums. Taxpayer claimed that the IRS assessed his taxes in 1994 after he late-filed his return and, therefore the limitations period would run out in 2004. The limitations period was tolled when Taxpayer filed for bankruptcy several times and then filed the necessary forms for a CDP hearing, the court determined. The present...

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