Eleventh Circuit Affirms IRS Determination to Proceed With Levy To Collect Unpaid Estate Tax Liability

The Eleventh Circuit, in an unpublished per curiam decision, affirmed a Tax Court decision that upheld an IRS decision to collect an estate's unpaid federal tax liability by levy.  The Court held that the IRS did not abuse its discretion when it rejected the estates offer to settle the $ 3 million liability for the estates remaining assets, worth $ 700,000.

See Estate of Jospeh L. Mangiardi v. Commissioner, No. 3958-08L, slip op. (T.C. Oct. 12, 2011).

By Derek Young, Associate Editor, Wealth Strategies Journal