Collection Due Process (“CDP”) hearings are crucial to taxpayers. Taxpayers have a right to a Collection Due Process hearing with the IRS Independent Office of Appeals before levy action is taken.
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The Tax Court held that FBAR penalties are not a tax imposed by the Code and, therefore, are not subject to the requirements of Secs. 6320 and 6330. Facts: Stephen C. and Judy A. Jenner were assessed ...