Tax News Update    Email this document    Print this document  

October 19, 2021

Partner who failed to challenge IRS assessment earlier is prohibited from challenging tax liabilities now, Tax Court concludes

In Ronald M. Goldberg v. Commissioner, Dkt. No, 12871-18L, the Tax Court has granted summary judgment for the IRS, finding that a partner in TEFRA partnerships is prohibited from challenging underlying tax liabilities representing his share of partnership-level adjustments because he had failed to challenge the assessment in an earlier Notice of Federal Tax Lien Filing and in earlier TEFRA proceedings and Tax Court litigation.


Goldberg v CIR