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BROWN v. C.I.R.

No. 23-70009.

116 F.4th 861 (2024)

Michael D. BROWN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed August 29, 2024.

Attorney(s) appearing for the Case

Steven R. Mather (argued), Mather Law Corporation, Beverly Hills, California, for Petitioner-Appellant.

Matthew S. Johnshoy (argued) and Arthur T. Catterall, Attorneys, Tax Division; David A. Hubbert, Deputy Assistant Attorney General; United States Department of Justice, Washington, D.C.; William M. Paul, Internal Revenue Service, Washington, D.C.; for Respondent-Appellee.

Dissent by Judge Bumatay

OPINION

A taxpayer served with a notice of tax lien on his property for unpaid taxes has the right to a due process hearing before an impartial officer under §§ 6320 and 6330 of the Tax Code. The purpose of such a hearing is to ensure that taxpayers are protected from wrongful IRS levies and sales of their...

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