Goldberg v. United States

Hamilton, Circuit Judge.

Plaintiffs Ronald M. Goldberg, Sherwin Geitner, and Phillip C. Leavitt, failed to pay federal income taxes they owed for a business partnership for the year 1994. After a criminal investigation touched that partnership, these plaintiffs reached a civil settlement with the Internal Revenue Service in'2003 by agreeing to pay back taxes. Nearly ten years later, however, they filed this suit seeking to invalidate the settlement and to collect other damages by claiming the IRS violated the tax code in assessing their tax liability. Plaintiffs seek relief in the form of both…