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 held that an individual was liable for frivolous return penalties for filing a zero return and sustained the IRS’s determination to proceed with collection action against him, finding no abuse of discretion by the IRS; the court declined to impose a frivolous argument penalty, finding that some of his arguments weren’t frivolous.
JOHN LEWIS HILL,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent