Babu v. Commissioner T.C. Memo. 2020-121
On August 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Babu v. Commissioner (T.C. Memo. 2020-121). The sole issue before the court in Babu v. Commissioner was whether the petitioner was liable for the substantial understatement accuracy-related penalty under IRC § 6662(a), IRC § 6662(b)(2), IRC § 6662(d)(2). Background to Babu v. Commissioner After earning a B.A. degree in finance, Mr. Babu attended law school at the University of Baltimore, graduating in 2005. During law school he took courses in tax law, participated in a tax clinic that assisted low-income taxpayers, and finished “with a pretty good understanding of tax.” Not only that, he worked for a tax mill during law school, and general counsel for five years after graduation. The petitioner held franchises for 19 separate tax mill locations. Business was good, until the DOJ dropped the hammer on the tax mill and its…
