Kelly v. Comm’r, No. 13353-21L, T.C. Memo 2022-73 | July 13, 2022 | Lauber | Short Summary: At issue in this collection due process (CDP) case is the propriety of the IRS’s collection actions and their refusal to grant the taxpayer’s leniency requests and requests for acceptance of a partial payment installment agreement. Ultimately, the First-Time Abatement, Failure To File, And Failed Leniency