Case: TEFRA Partnership Case Gave Partner Prior Opportunity to Challenge Liabilities (T.C. Memo) (IRC §6330)

Partner precluded from challenging his underlying liabilities because he was a party to a partnership’s TEFRA proceedings which gave him a prior opportunity to challenge the taxes, the U.S. Tax Court held in a memorandum opinion. Partnership had certain I.R.C. §45 credits denied. The IRS sent the partnership an FPAA. Partner did not receive a copy. The IRS denied the pass-through of the credits on Partner’s return. The IRS did not send a notice of deficiency. Partner, after receiving a levy notice, requested a collection due process hearing where he challenged the underlying liabilities. The Settlement officer determined that ...