IRS Fails to Prove Fraudulent Intent; Fraud Penalties Inapplicable
The United States Tax Court held that the IRS failed to prove a couple’s fraudulent intent in underpaying their taxes, and they are not liable for fraud penalties; the court sustained an accuracy-related penalty for negligence, finding that they understated their tax liability for one year by failing to report income and claiming unsubstantiated deductions.
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.
JAMES A. ERICSON AND REBECCA A. ERICSON,
Petitioners v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent