The U.S. Tax Court properly sustained a notice of federal tax lien to collect unpaid penalties for filing frivolous returns, the U.S. Court of Appeals for the Ninth Circuit held in an unpublished opinion, affirming the Tax Court’s decision. Taxpayer had submitted returns indicating that the self-assessment of taxable income was substantially incorrect and based on frivolous positions. [Smith v. Commissioner, No. 22-70051 (9th Cir. July 10, 2023)]
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