John Ryskamp v. Commissioner of IRS
Court of Appeals for the D.C. Circuit
1Opinion of the Court
Opinion for the Court filed by Circuit Judge PILLARD.
Dissenting opinion filed by Circuit Judge BROWN.
PILLARD, Circuit Judge:
John Ryskamp underpaid federal income taxes for several years and did not respond to the Internal Revenue Service’s demand for payment. The Internal Revenue Code provides that, before the IRS levies against the taxpayer’s property to collect unpaid taxes, the taxpayer is entitled to what the IRS refers to as a Collection Due Process (CDP) hearing before an impartial officer of the IRS Appeals Office. 26 U.S.C. §§ 6330, 6331(d). Subsection 6330(g) of the Code provides,…
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