Polselli v. Internal Revenue Service
A revenue officer summoned the bank records of a debtor's wife, his lawyers and a company he used. Nobody got notice. A unanimous Supreme Court said none was required.
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United States v. National Bank of Commerce
One co-owner owed the IRS $856.61. The Supreme Court held the IRS could levy the whole joint account and sort out ownership later.
472 U.S. 713 (1985)
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Browse Cases by Topic
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Recent Case Explainers
Case libraryBoechler, P.C. v. Commissioner
A law firm filed its Tax Court petition one day late. A unanimous Supreme Court held the 30-day CDP deadline is not jurisdictional and can be equitably tolled.
Commissioner v. Zuch
Jennifer Zuch fought the IRS for years over $50,000 in payments. When her later refunds wiped out the balance, the Supreme Court held the Tax Court could no longer hear her case.
Vinatieri v. Commissioner
A sick, low-income taxpayer had $14 in cash and a car worth $300. Appeals sustained the levy because she had unfiled returns. The Tax Court said that was an abuse of discretion.
Hoyle v. Commissioner
A taxpayer said he never got a notice of deficiency. Appeals checked a box. The Tax Court said the verification requirement means more than that.
Cheshire v. Commissioner
A wife knew about her husband's $229,924 retirement payout and how it was spent. She trusted him on the tax. The Fifth Circuit said that was not enough.
Porter v. Commissioner
The IRS denied a mother of two relief from a $1,070 penalty tax on her husband's IRA withdrawal. The Tax Court changed its standard of review and granted relief.
Lantz v. Commissioner
A widow who did nothing wrong lost her chance at innocent spouse relief because of a regulatory deadline. The Seventh Circuit upheld it. Congress later rewrote the rule.
United States v. Boyle
An executor did everything right except check the filing date himself. His lawyer missed it. The Supreme Court upheld a $17,124.45 penalty.
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