Goldberg v. Comm’r, T.C. Memo. 2021-119 | October 19, 2021 | Paris, J. | Dkt. No. 12871-18L
Short Summary: Mr. Goldberg was an investor and partner in two oil and gas partnerships. The two partnerships were subject to TEFRA audits, and the IRS timely assessed taxes and penalties related to the TEFRA audits against Mr. Goldberg. Later, the IRS issued notices of federal tax lien (NFTL) with respect to the taxes and penalties. Mr. Goldberg failed to timely challenge the NFTL. Later, after the IRS issued a notice of intent to levy, Mr. Goldberg timely filed a request for a Collection Due Process (CDP) hearing. During the CDP hearing, Mr. Goldberg challenged the amount of taxes and penalties that he owed.
Key Issues:
- Whether Mr. Goldberg is prohibited from challenging his underlying tax liabilities in the CDP hearing?
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