Goldberg v. Commissioner T.C. Memo. 2021-119
On October 19, 2021, the Tax Court issued a Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2021-119). The primary issue presented in Goldberg v. Commissioner was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC § 6320 or because of his nonparticipation in an even earlier TEFRA proceedings and Tax Court litigation. Held: Sorry, Ronny. You had your shot(s). Background to Goldberg v. Commissioner Ronald Goldberg, the petitioner in this case, was a partner in two oil and gas partnerships. The partnerships were both subject to audit and litigation procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) (IRC § 6221 through IRC § 6234),[1] which resulted in administrative adjustments to the partnerships’ information returns. Because partnerships are…
