David H. Melasky & Audrey Melasky v. Commissioner

151 T.C. No. 8

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. R mailed Ps a notice of determination. Ps owed significant back taxes dating to the mid-1990s. As payment for their more recent taxes, Ps hand delivered a check to R and designated it for the 2009 tax year. Four days later, and before cashing the check, R levied on their bank account. The check subsequently bounced when R applied the levy proceeds to an earlier year. Held: A challenge to the proper crediting of a…