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.
The Tax Court held a fugitive liable for a fraud penalty for one tax year, finding that there was clear and convincing evidence of his fraudulent intent to underpay his taxes, but declined to a impose a fraud penalty or addition to tax for fraudulent failure to file for another year, finding that his return signed by his partner was invalid.
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent