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Appeals Tax Liens

Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

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An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

Foodman CPAs & Advisors

¿Puedes Apelar Al IRS?

Los contribuyentes tienen derecho a apelar al IRS. Entender cómo apelar al IRS es fundamental y los contribuyentes deben considerar contratar representación para disminuir los riesgos de litigio. Sólo los abogados, contadores...more

Foodman CPAs & Advisors

Can You Appeal The IRS?

Taxpayers have the right to appeal the IRS. Understanding how to appeal the IRS is critical and Taxpayers ought to consider retaining representation in order to diminish the risks of litigation. Only attorneys, certified...more

Dorsey & Whitney LLP

The Supreme Court Update - May 25, 2023

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Today, the Supreme Court of the United States issued three decisions: Tyler v. Hennepin County, No. 22-166: This case involved the Fifth Amendment’s “Takings Clause” in the context of seizing property to collect unpaid...more

Gerald Nowotny - Law Office of Gerald R....

The Letter

Overview - Most of you know that I am a big music fan. I have always liked Joe Cocker. The song The Letter is a song that was originally performed by The Box Tops and was a Number 1 hit in 1967. The song was covered by Joe...more

Bricker Graydon LLP

Ants arriving at the picnic: U.S. 6th Circuit Court of Appeals finds merit in federal “takings” claim filed against county land...

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In May 2021, the federal 6th Circuit Court of Appeals in Cincinnati sent a county land bank case back to the district court in Dayton for reconsideration. Rejecting the winning argument at the lower level - that the owner of...more

Miller Canfield

Michigan Court of Appeals Holds That Development Agreement Obligations are Extinguished in Tax Foreclosure

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The Michigan Court of Appeals recently held that assessments on a property under a development agreement between a city and the property's former owner did not survive a tax foreclosure and therefore were not liens against...more

Patton Sullivan Brodehl LLP

Is an APN Number Sufficient to Describe Property in a Deed of Trust?

To be enforceable, a deed of trust must sufficiently describe the real property security. There are several different ways to describe real property. Commonly used methods include referring to a block and lot number from a...more

McDermott Will & Emery

Sacked in Tax Court! Procedural Missteps by the IRS Leave the Government’s Blindside Exposed

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In Kearse v. Commissioner, T.C. Memo 2019-53, the Tax Court held the Internal Revenue Service (IRS) abused its discretion as part of the taxpayer’s Collection Due Process hearing (CDP hearing) because the Appeals officer...more

Bennett Jones LLP

Property Tax Priorities in Alberta Insolvency Proceedings: Current Uncertainty

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Recent decisions of the Court of Queen's Bench of Alberta have put into question the priority of municipal property taxes in insolvency proceedings. Two such decisions are the subject of pending appeals. A third recent...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

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There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

Burr & Forman

Appealing A South Carolina State Tax Case: Payment Or Bond?

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Taxpayers who disagree with a proposed tax assessment issued by the South Carolina Department of Revenue (SCDOR or DOR) may or may not be able reach an agreement at the administrative level. When taxpayers and SCDOR cannot...more

Ward and Smith, P.A.

Federal Tax Liens In Foreclosure Proceedings

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Henkel v. Triangle Homes is a North Carolina Court of Appeals case with dueling tax foreclosure proceedings involving the same property. One foreclosure proceeding was for unpaid municipal taxes and the other for unpaid...more

Womble Bond Dickinson

N.C. Court of Appeals: Absent Notice to the Federal Government, Foreclosure for Unpaid Local Taxes Won't Extinguish Federal Tax...

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North Carolina is a "pure race" state, for real estate title purposes. That is, “first to record an interest in land holds an interest superior to all other purchases for value, regardless of actual or constructive notice as...more

Ballard Spahr LLP

CFPB files amicus brief in Fifth Circuit TILA case

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The CFPB has filed an amicus brief in Billings v. Propel Financial Services, LLC, a case on appeal to the U.S. Court of Appeals for the Fifth Circuit. The issue in the case is whether a private lender extends“consumer credit”...more

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