Case: Taxpayer Cannot Relitigate Tax Debt Underlying Decade Old Judgment, Motion to Reopen Discovery Denied (S.D. Cal.)

Individual taxpayer cannot reopen discovery to obtain information about the audit or auditor related to a tax debt that was reduced to a judgment in 2012, a district court held, denying taxpayer’s motion. When the U.S. sought to foreclose on taxpayer’s real property to enforce its judgment lien against taxpayer, taxpayer filed a motion to reopen discovery in his own case and subpoena an individual in his wife’s separate innocent spouse case. Any information taxpayer could obtain in his own case would be irrelevant at this stage, and taxpayer failed to meet the good cause standard for modifying a schedule. ...