Agility Network Services, Inc. v. United States

OPINION

ROGERS, Circuit Judge.

After receiving a notice of federal tax lien and a notice of intent to levy, taxpayers Agility Network Services, Inc., Cinnamon Denny, and Chandler Denny request-' ed that the IRS hold a Collection Due Process hearing. The IRS took five months to process the request, and when the Office of Appeals finally held a hearing, the presiding agent refused to discuss multiple issues with the taxpayers. They were still dissatisfied after a second hearing before a different agent and sued the Government for the IRS agents’ alleged misbehavior under 26 U.S.C. § 7433, which…