Tax News

CCH (cch.taxgroup.com) reports:

Married taxpayers were not entitled to have their Collection Due Process (CDP) appeal heard under the Code Sec. 7463(f)(2) small case procedures because their unpaid tax on the date of the determination notice exceeded $50,000. Although the couple disputed less than $50,000, the amount of the unpaid tax on the date of the determination notice, rather than the amount in dispute, governed their eligibility for small case designation.
M.P. Leahy, 129 TC No. 8, Dec. 57,105
Other References:
Code Sec. 6330
CCH Reference - 2007FED ¶38,184.60
Code Sec. 7463
CCH Reference - 2007FED ¶42,119.16
Tax Research Consultant
CCH Reference - TRC LITIG: 7,002