Our Country Home Enterprises, Inc. v. Commissioner of Internal Revenue

Tax Court did not err in granting Commissioner’s motion for summary judgment in Collection Due Process (CDP) proceeding in which plaintiff-taxpayer challenged IRS imposition of penalty under section 6707A of Tax Code regarding taxpayer’s failure to report its participation in employee-benefit plan on its 2007 tax return. Record showed that taxpayer had previously challenged its liability for said penalty in administrative hearing before IRS Office of Appeals, and Tax Court could properly determine that taxpayer’s earlier liability challenge precluded taxpayer from challenging same liability in CDP proceeding.