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Archive for Tax Court Arguments

Tax Court In Brief: Danger Of Raising Frivolous Arguments Before The Tax Court

Tax Court In Brief: Danger Of Raising Frivolous Arguments Before The Tax Court

Hatfield v. Comm’r, T.C. Memo. 2022-59 | June 13, 2022 | Lauber, J. | Dkt. Nos. 7327-20, 1500-21

Opinion

Short Summary:  Petitioners were a married couple filing joint federal income tax returns for tax years 2013 and 2014. Husband was employed as a radiologist. Petitioners failed to report husband’s wages as gross income on their federal income tax returns for 2013 and 2014.

The Internal Revenue Service (IRS) examined petitioners’ 2013 and 2014 returns and assessed federal income tax based on the wages reported on the Forms W-2, Wage and Tax Statement, that husband’s employer had filed with the IRS for each of those years. In addition, the IRS found that petitioners were liable for additional tax for early withdrawals from an individual retirement account in 2013 and 2014 and that petitioners had failed to report taxable interest in 2014. The IRS also imposed accuracy-related penalties for both years and an addition to tax for petitioners’ failure to timely file their 2014 return.

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