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 United States Tax Court upheld the IRS’s deficiency determination and imposed an accuracy-related penalty against a couple who claimed deductions for business use of their vehicles, finding the couple hadn’t met the substantiation requirements of Code Section 274(d); the court declined to impose a fraud penalty, finding the IRS hadn’t met its evidentiary burden.
JIM F. FLAKE AND MARTHA N. FLAKE,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent