Dalton, Jr. v. Commissioner of IRS

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• CDP process neither allows for discovery nor brings together all interested parties, and doesn’t allow cross-examination
• “The CDP process neither allows for discovery, nor does it bring before the IRS all of the parties in interest[.]”
• \[A] court should set aside determinations reached by the IRS during the CDP process only if they are unreasonable in light of the record compiled before the agency\
• listing a similar set of factors

Source: CourtListener parenthetical corpus (CC0).