United States Eighth Circuit

A determination that the IRS had abused its discretion in imposing a levy on a taxpayer after finding him in default of an offer-in-compromise is reversed where it was inappropriate for the tax court to set aside an IRS appeals officer's decision.

Appellate Information

• Decided 03/08/2006
• Published 03/08/2006

Judges

• COLLOTON, Circuit Judge., Before ARNOLD, McMILLIAN, and COLLOTON, Circuit Judges.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Francesca U. Tamami, UDSOJ, Tax Division, argued, Washington, DC (Teresa E. McLaughlin, USDOJ, Tax Division, Washington, DC, on the brief), for appellant.


• For Appellees:
  
• Gregory B. Graham, argued, Little Rock, AR. (Laurie M. Boyd, Little Rock, AR, on the brief), for appellee.