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What is a Prior Opportunity to Contest the Liability for Purposes of Collection Due Process?
November 3, 2016
Original appeared in Procedurally Taxing
Back in February of this year, Carl Smith noted in a guest post that three Circuit Courts of Appeal would be considering the question of the circumstances under which a taxpayer is barred from challenging the merits of the underlying tax liability in a Collection Due Process case under section 6330(c)(2)(B) because of a “prior opportunity” to contest the underlying liability. Our firm was retained to handle these appeals. Briefing in all three cases is now complete. Oral argument in the 7th Circuit case is set for November 9. Oral argument in the 10th Circuit case is set for November 14. Oral argument in the 4th Circuit case is set for the last week of January.
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