Monday, November 11, 2013
Isley Brother (of Isley Brothers) CDP Case Decision with Tax Procedure Issues (11/11/13)
Earlier today, I posted a blog on the Federal Tax Crimes Blog, IRS Authority to Settle After Referral to DOJ Tax (11/11/13), here. In that blog, I point readers to an excellent blog by Peter Reilly -- An Isley Brother In Tax Court - Does Tax Crime Pay (Forbes Taxes 11/10/13), here. Peter discusses the recent decision in Isley v. Commissioner, 141 T.C. No. 11 (2013), here. I refer readers to Peter's excellent discussion of the issues in the case. In my Federal Tax Crimes Blog entry, rather than re-covering the ground that Peter does so well -- I urge readers to read his blog -- I focused on one aspect of the case that particularly interested me -- the application of Section 7122(a), here, that gives DOJ authority over compromises of criminal and civil matters that have been referred to DOJ. I won't repeat my discussion here, but refer interested readers to that blog entry.