Case: Petitioner Liable for Income Tax Deficiencies, Civil Fraud Penalties (T.C. Memo) (IRC §6663)

Petitioner was liable for income tax deficiencies and civil fraud penalties, the U.S. Tax Court held, granting summary judgment for the government. Petitioner, a medical doctor, did not file timely tax returns or pay taxes owed for multiple years, failed to cooperate with an IRS examination, and belatedly submitted returns that fraudulently understated income. The government issued a notice of deficiency determining tax deficiencies and civil fraud penalties under I.R.C. §6663. Petitioner petitioned the Tax Court but failed to respond to the government’s summary judgment motion or appear for hearings. The court held that the government met its burden to ...