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Robinette v. Commissioner of the IRS

439 F.3d 455 (2006)

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Robinette v. Commissioner of the IRS

United States Court of Appeals for the Eighth Circuit

439 F.3d 455 (2006)

Facts

James Robinette (plaintiff) did not file income-tax returns for several years and, as a result, owed over $1 million in back taxes, penalties, and interest. Eventually, the Internal Revenue Service (IRS) (defendant) placed Robinette into default and notified Robinette of its intention to impose a levy on his property. Section 6330 of the Internal Revenue Code required the IRS to give a taxpayer a collection due-process hearing before imposing a levy on the taxpayer’s property. In accordance with § 6330, the IRS conducted a collection due-process hearing for Robinette. The IRS appeals officer in charge of the hearing examined Robinette’s file, gathered relevant documents, and wrote an explanatory memorandum recommending that the levy be imposed on Robinette’s property. The IRS Office of Appeals approved the levy. Robinette appealed to the United States Tax Court under § 6330(d)(1), arguing that the appeals officer abused his discretion in deciding to impose the levy. The tax court conducted a de novo hearing at which it entered new evidence and decided in favor of Robinette. The IRS appealed.

Rule of Law

Issue

Holding and Reasoning (Colloton, J.)

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