On September 10, 2020, the Tax Court issued a Memorandum Opinion in the case of Belanger v. Commissioner (T.C. Memo. 2020-130). The primary issues before the court in Belanger v. Commissioner were (1) whether the IRS timely mailed a notice of deficiency to the petitioner; (3) whether the petitioner had unreported income; and (3) whether the petitioner was liable for civil fraud penalties. Background to Belanger v. Commissioner The petitioner is French-Canadian, so he can’t be too bad a guy, eh. He is not, however, the brightest bulb in the shed. He dropped out of high school in 10th grade, and though he went the trade school and founded a successful foundation…company, that is to say a company that laid foundations, his method of “accounting” left much to be desired. The “Step Method” of Accounting The petitioner did not use QuickBooks or other accounting software to maintain Number One Foundations’…