Untimely CDP Arguments Worth Consideration
admin2018-12-13T17:52:30+00:00By Eli S. Noff, Esq., CPA, Partner Mary Lundstedt, Esq. The taxpayer in Berkun v. Commissioner1 ultimately raised two collection due process arguments too late for consideration on appeal, but the Eleventh Circuit apparently found them worthy enough to highlight in a published opinion. Although the Eleventh Circuit uses a [...]