David H. Melasky & Audrey Melasky v. Commissioner

151 T.C. No. 9

UNITED STATES TAX COURT DAVID H. MELASKY AND AUDREY MELASKY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12777-12L. Filed October 10, 2018. This CDP case involves Ps’ 2006, 2008, and 2009 income tax liabilities. Ps gave R a check which they asked to have applied against their 2009 income tax liability. Before the check was deposited, R levied on Ps’ bank account (against which the check had been drawn) with respect to other tax liabilities Ps owed. Ps’ check subsequently failed to clear. R applied the proceeds of the levy against Ps’ 1995 income tax…