USA Financial Services, Inc. v. United States Internal Revenue Service

MEMORANDUM ORDER

LEE, District Judge.

THIS MATTER is before the Court on Defendant, the Internal Revenue Service’s (“IRS”) Motion for Summary Judgment of USA Financial Services, Inc.’s (“USA FSI”) appeal of a collection due process hearing (“CDP”). This is a tax collection case where the delinquent taxpayer, USA FSI contends that the IRS’s Appeals Officer abused his discretion by rejecting USA FSI’s proposed installment payment agreement for unpaid taxes and penalties in lieu of a tax levy. The issues before the Court are: (1) whether the Court should wait to hear Defendant’s Motion for Summary…