The U.S. Court of Appeals for the First Circuit has adopted a deferential standard for reviewing Internal Revenue Service collection due process proceedings one based on reasonableness, not necessarily correctness.
On June 20, a unanimous panel reversed a 2008 U.S. Tax Court judgment that overruled the IRS’s rejection of two taxpayers’ offer to settle their tax bill for “pennies on the dollar.” It also reversed the Tax Court’s award of attorney fees to the taxpayers.
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