The United States Tax Court Determines a Disbarred CPA Liable for Penalties for Fraud, Frivolous Arguments
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, imposing a $25,000 frivolous argument penalty, held that a CPA who was disbarred from practicing before the IRS is liable for additions to tax for fraudulent failure to file returns, finding that he had knowledge of his tax-paying responsibilities and failed to provide a nonfraudulent explanation for his behavior.
JOSEPH R. BANISTER,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent