Ronald Goldberg, et al. v. United States

For 26 U.S.C. § 7433(a), is the assessment of a tax an activity “in connection with” the collection of that tax? 26 U.S.C. § 7433(a) provides: If, in connection with any collection of Federal tax with respect to a taxpayer, any officer or employee of the Internal Revenue Service recklessly or intentionally, or by reason of negligence, disregards any provision of this title, or any regulation promulgated under this title, such taxpayer may bring a civil action for damages against the United States in a district court of the United States. Except as provided in section 7432, such civil action shall be the exclusive remedy for recovering damages resulting from such actions.

Under the informal-claim doctrine, must a taxpayer who files a suit contesting a tax under 26 U.S.C. § 7422 after the statute of limitations has expired file a formal, amended claim before suit is filed?