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

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 sustained deficiencies and additions to tax for failure to file returns and pay taxes against an individual, holding him in default for failing to comply with court rules and failing to appear; the court imposed a $25,000 penalty against him for presenting frivolous tax-protester arguments and initiating groundless proceedings.

PETER H. JONES,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent


PETER HENRY JONES,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-101

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

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 the operator of a bee and wasp removal business maintained insufficient records to substantiate business deductions and the IRS was entitled to use the bank deposits method to reconstruct the income of the business and impose additions to tax under Code Section 6651 and 6654.

GEORGE R. BRISTOL,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-84

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

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

T.C. Memo. 2014-76

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

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 StatesTax Court, imposing a frivolous argument penalty, found no abuse of discretion by the IRS in sustaining a levy against a couple and held that the IRS satisfied its obligation to provide them with records of assessment; the couple’s attorney must show cause why he shouldn’t be required to pay excessive costs to the IRS under section 6673(a)(2).

LEONARD L. BEST AND EVELYN R. BEST,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-72