A Partnership failed to pay employment taxes for its employees and within the proper time limitations, the I.R.S. assessed the taxes against the Partnership, but not against individual partners. Later, the IRS tried to collect the taxes from the individual partners. The partners claimed that they were not liable because the I.R.S. did not assess them individually as taxpayers and the time limits in which to do so had expired. Why did partners claim they should have been individually assessed? Why did I.R.S. claim it was not necessary? How did court resolve this?
See U.S. v. Galletti 541 U.S. 114, 124 S.Ct.1548 (2004).