Why Reading IRS Notices Matter

In her December 2025 TaxStringer article for the New York State Society of CPAs, Ellen Brody highlights a U.S. Tax Court case that serves as a cautionary tale for taxpayers who fall behind on filings or ignore IRS correspondence.

The case, Carol Rae Foulds v. Commissioner of Internal Revenue (2025),  is about a taxpayer who failed to file returns for multiple years and later tried to dispute the IRS’s assessments during a Collection Due Process hearing. Because she had received—but never responded to—statutory notices of deficiency, the court ruled that she lost the right to challenge the underlying tax liabilities. Without filed returns, financial documentation, or proposed collection alternatives, the court found that the IRS Appeals Office had no basis to help her, and upheld the tax levy against her.

A helpful reminder for practitioners and taxpayers alike: read the fine print, stay current, and never let a statutory notice sit unopened.

Read the article here.