Cropper v. Commissioner

MORITZ, Circuit Judge.

When the Internal Revenue Service notified James Cropper of its intent to collect unpaid taxes by levying his property, Cropper requested a collection due process (CDP) hearing with the IRS Office' of Appeals. The Office of Appeals determined that the IRS could proceed with the proposed levy. Cropper sought judicial review, and the United States Tax Court sustained the Office of Appeals’ determination. Because we agree with the Tax Court that the Office of Appeals didn’t abuse its discretion in determining that the IRS could proceed with the levy, we affirm.

Background

Prel…