BOECHLER, P.C. v. C.I.R.

No. 20-1472.

142 S.Ct. 1493 (2022)

596 U.S. 199

BOECHLER, P.C., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided April 21, 2022.


Attorney(s) appearing for the Case

Melissa Arbus Sherry , Washington, DC, for petitioner.

Jonathan C. Bond , for respondent.

Melissa Arbus Sherry , Counsel of Record, Caroline A. Flynn , Amy Feinberg , Latham & Watkins LLP, Washington, DC, for Petitioner.

Elizabeth B. Prelogar , Solicitor General, Counsel of Record, David A. Hubbert , Deputy Assistant Attorney General, Curtis E. Gannona , Deputy Solicitor General, Jonathan C. Bond , Assistant to the Solicitor General, Francesca Ugolini , Joan I. Oppenheimer , Janet A. Bradley , Judith A. Hagley , Attorneys, Department of Justice Washington, DC, for Respondent.


The Internal Revenue Service can seize taxpayer property to collect tax debts. Before it does so, however, the taxpayer is typically entitled to a "collection due process hearing"—a proceeding at which the taxpayer can challenge the levy or offer collection alternatives like payment by installment...

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