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