On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Liu v. Commissioner (T.C. Memo. 2020-31). The single issue presented in Liu v. Commissioner was whether the Tax Court had jurisdiction to determine whether petitioners were liable for interest on the deficiencies determined by the IRS because the IRS filed an erroneous notice of Federal tax lien (NFTL). Background to Liu v. Commissioner Petitioners each owned a 50% interest in