United States v. Brabant-Scribner, No. 17-2825 (8th Cir. 2018)
Annotate this CaseOffer of compromise is not a reasonable alternative to seizure under 26 C.F.R. sec. 301.6334-1(d)(1), which requires an alternative for collection, not an alternative to collection. The Eighth Circuit affirmed the district court's grant of the government's petition for permission to levy taxpayer's home and to apply the proceeds toward her debt. The court rejected taxpayer's claim that the government must respond to her offer to compromise the debt before the court may levy on her principal residence.
Court Description: Stras, Author, with Wollman and Kelly, Circuit Judges] Tax ? Levy. Taxpayer's claim that government must respond to her offer to compromise the debt before court may levy on her principal residence is rejected. Offer of compromise is not a reasonable alternative to seizure under 26 C.F.R. sec. 301.6334-1(d)(1), which requires an alternative for collection, not an alternative to collection.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.