United States Tax Court Decision for the Week – You be the Judge

Individual Is Held Liable for Frivolous Submission Penalties

The United States Tax Court upheld an IRS determination to sustain the collection by levy of an individual’s unpaid liability for assessed section 6702 frivolous return penalties and interest, finding that the individual’s argument that his compensation wasn’t taxable income was frivolous.

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

MARK A. LOVELY,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2015-135