FBAR Penalties and the Treasury Offset Program: Tax Court Affirms IRS’s Denial of CDP Hearing
Introduction: In Jenner v. Commissioner, 163 T.C. 7 (Oct. 22, 2024) (link to opinion), the U.S. Tax Court held that the Internal Revenue Service (“IRS”) was under no obligation to provide a husband and wife with a collection due process (“CDP”) hearing prior to offsetting Social Security benefit payments under the Treasury Offset Program (TOP)….