The Tax Court in Brief October 18 – October 22, 2021

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The Tax Court in Brief October 18 – October 22, 2021

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

For a link to our podcast covering the Tax Court in Brief, download here or check out other episodes of The Freeman Law Project.

Tax Litigation: The Week of October 18 – October 22, 2021


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:

Primary Holdings:

Key Points of Law:

Insight: The Goldberg case provides a helpful reminder to taxpayers to challenge the existence or amount of any underlying liabilities at the first CDP hearing.  If a taxpayer waits until the second CDP hearing to make such a challenge, the taxpayer will likely be barred from presenting the issue under federal tax law.


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