Keith and Cherie Orum v. Commissioner of Internal Revenue

Summary

The Court dismissed the 1998 challenge for lack of jurisdiction because petitioners did not timely request a collection due process hearing after the first levy notice, and the later equivalent-hearing decision letter was not a reviewable determination. The Court sustained the proposed collection action for 1999, holding that the settlement officer did not abuse her discretion in rejecting petitioners' proposed installment agreement and offer-in-compromise based on incomplete financial information, prior default, and sufficient apparent income and assets. No separate opinions were filed.