Brown v. Commissioner, 158 T.C. No. 9| June 23, 2022 | Lauber, J.| Dkt. No. 11519-20L Opinion Summary: Michael Brown had tax liability exceeding $50 million. This case regards that liability, collection due process (CDP), and review of a determination by the IRS to reject an offer-in-compromise (OIC). On November 9, 2017, the IRS issued petitioner Notice Tax Court In Brief: Offer In Compromise Rejected