Jonathan Amitrano Published in TaxNotes This Week

August 4, 2026

Taylor Nelson Amitrano LLP is delighted to announce that managing partner Jonathan Amitrano's article, "Proposed Changes to Collection Due Process Regulations to Ensure CDP Rights," co-authored with Phillip J. Colasanto of Charles Russell Speechlys US LLP, was published in TaxNotes on August 3, 2026.

In this article, Jonathan and Phillip propose amendments to treasury regulations that would expand collection due process protections by requiring the IRS to provide pre-levy notice and hearing rights to all persons whose property is subject to proposed levy—not just assessed taxpayers. Their proposal examines how the current regulatory framework leaves third parties without meaningful pre-levy administrative review. The article also offers a regulatory solution designed to better align IRS procedures with the plain language, purpose, and due process protections embodied in Internal Revenue Code section 6330.

Read the full article here.

Congratulations to Jonathan and Phillip on your important contribution to this significant conversation surrounding taxpayer rights and tax administration.

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