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GREENBERG v. C.I.R.

No. 20-13001.

10 F.4th 1136 (2021)

David B. GREENBERG, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, David B. Greenberg, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee, David B. Greenberg, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee, David B. Greenberg, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee, David B. Greenberg, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

August 20, 2021.

Attorney(s) appearing for the Case

Steven Ray Mather , Mather Law Corporation, LOS ANGELES, CA, for Petitioner-Appellant.

Geoffrey Klimas , Anthony T. Sheehan , Bruce R. Ellisen , U.S. Department of Justice, Appellate Section Tax Division, WASHINGTON, DC, Paul Colleran , Benjamin R. Poor , Office of Chief, Counsel, IRS, BOSTON, MA, Michael J. Desmond , Chief Counsel — IRS, WASHINGTON, DC, for Respondent-Appellee.

Before NEWSOM, BRANCH, and LAGOA, Circuit Judges.

This appeal primarily concerns the interpretation of provisions of the Tax Equity and Fiscal Responsibility Act of 1982 ("TEFRA"), Pub. L. No. 97-248, 96 Stat. 324, in effect during the tax years at issue.1 David Greenberg appeals the Tax Court's memorandum opinion upholding adjustments contained...

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