What is a Genuine Opportunity to Dispute a Tax Liability?

Taxpayers are able to dispute a tax liability before the IRS can take certain collection actions. But what if the IRS does not afford the taxpayer with a genuine opportunity to dispute the liability as required by law? The court addresses this in Dood v. Commissioner, T.C. Memo. 2019-107. Facts & Procedural History The taxpayer… Continue reading What is a Genuine Opportunity to Dispute a Tax Liability?

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