On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins v. Commissioner were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2) whether the petitioners are liable for additions to tax for failing to timely file their returns; and whether petitioner-husband is liable for the civil fraud penalty of IRC § 6663(a). Intro Note to Collins v. Commissioner There is a lot packed into Judge Ashford’s 57-page opinion. Ultimately, the court found for the IRS on every issue, including the civil fraud penalty, but it was not without substantial work that Judge Ashford reached his conclusions. The arguments on the part of the petitioners are thoroughly impressive considering that they represented themselves. They were not frivolous, and they certainly made the IRS…