United States Tax Court
Hough Beck & Baird, Inc.
July 8, 2026
Summary
The Court held that the Commissioner properly used a supplemental assessment to recover employment taxes that had been mistakenly assessed as zero and refunded to petitioner. Because the erroneous assessment misstated petitioner’s liability by the entire amount of its reported employment tax, it was imperfect in a material respect, permitting a timely supplemental assessment and levy. The Court therefore granted respondent’s motion for summary judgment, denied petitioner’s motion, and sustained the proposed levy.