U.S. Tax Court Upholds Fraudulent Failure to File Penalties for Unreported Income

The U.S. Tax Court, in a memorandum decision, held that a taxpayer fraudulently failed to file federal income tax returns and was liable for additions to tax under I.R.C. §6651(f), granting the IRS’s motion for summary judgment. Taxpayer, an individual, operated a corporation that hosted purported breast cancer fundraising events nationwide using promotional models who falsely represented that donations would support cancer research, while Taxpayer actually controlled the funds for personal use. The taxpayer received unreported income for the years at issue from bank deposits, credit card sales, and corporate distributions, and he failed to file any tax returns since ...