United States Eighth Circuit

In suits brought to require the IRS to enter installment agreements in lieu of levying on plaintiff-taxpayer's property, summary judgment for the government is affirmed over claims that an IRS appeals officer failed to consider plaintiff's current ability to make payments under a proposed installment agreement, and failed to balance the need for efficient tax collection against the need to minimize the intrusiveness of such collection.

Appellate Information

• Decided 08/14/2007
• Published 08/14/2007

Judges

• JOHN R. GIBSON, Circuit Judge., Before WOLLMAN, JOHN R. GIBSON, and MURPHY, Circuit Judges.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Neal J. Shapiro, argued, Saul A. Bernick, on the brief, Minneapolis, MN, for appellant.


• For Appellees:
  
• Counsel who presented argument on behalf of the appellee was Richard L. Parker, argued, Andrea R. Tebbets, on the brief, Dept. of Justice, Tax Div., Washington, D.C., for appellee.