Fred Deutsch v. Commissioner of Internal Revenue

JOSÉ A. CABRANES, Circuit Judge.

Petitioner Fred Deutsch appeals a decision of the United States Tax Court granting the motion for summary judgment of respondent Commissioner of Internal Revenue (“Commissioner”). See Deutsch v. Comm’r of Internal Revenue, 2006 WL 345848 (Tax Ct. Feb. 15, 2006). The Tax Court concluded that petitioner could not challenge the extent of his tax liabilities for 1995, 1996, and 1997 because he previously had an opportunity to dispute those liabilities.

Petitioner’s argument that he should be permitted to challenge the government’s assessment of his tax liability for…