§7524 — Annual notice of tax delinquency

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Not less often than annually, the Secretary shall send a written notice to each taxpayer who has a tax delinquent account of the amount of the tax delinquency as of the date of the notice.

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FOLLOWED Richard C. Mathews, Petitioner T.C. Memo. 2021-85 · 2021

Mathews for tax year 2012, section 7524 provides that a “taxpayer who has a tax delinquent account” shall receive notice not less often than annually “of the amount of the tax delinquency as of the date of the notice.” The balance due reminder offers no insight into the nature of the delinquency, e.g., whether it stemmed from deficiency proceedin