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Taxpayer Cannot Contest 6707A Penalties During CDP Process

04 / 15 / 2017

The Tax Court has ruled in Bitter v. IRS, T.C. Memo 2017-46, that if a taxpayer looks to "protest" the assessment of 6707A penalties (for failure to disclose individual participation in a reportable transaction), he or she will be barred from contesting the liability in a latter Collection Due Process (CDP) hearing, even if the results of the determinations reached during the CDP process are appealed to the United States Tax Court.