Tax, Administraive
Although an irregularity in the postal forms prevented a presumption of receipt upon mailing, an agency appeal holding that the totality of the evidence indicated mailing was not an abuse of discretion, and since the statute imposes an affirmative duty on the recipient to challenge the mailing, the loss of the presumption of receipt does not prevent the levy.
Cropper v. CIR
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.