Fourth Circuit Clarifies the Role of the Collection Due Process Hearing

Overview


Joshua Ellenberg wrote this bylined article on the Fourth Circuit’s Iames v. Commissioner, upholding the US Tax Court’s limiting of collection due process (CDP) hearings to challenge tax liabilities. “In Iames, the Tax Court may have been reacting to the explosive growth of CDP cases overall on the court’s docket, and trying to ensure those cases are limited to their statutory purpose,” Mr. Ellenberg wrote, advising taxpayers “to raise any challenges to liability as early as possible.”