On April 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Flynn v. Commissioner (T.C. Memo. 2021-43). The primary issue presented in Flynn v. Commissioner was whether the petitioner’s failure to file returns for 1999, 2000, and 2001 was fraudulent. Tax Court's Holding in Flynn v. Commissioner:   It’s a Damn Conspiracy (No, Really, It Is) The petitioner took part in a bit of a criminal conspiracy, which bilked 577 suckers (investors, rather) out of $20.7 million between 1999 and 2001. The petitioner and his co-conspirators represented to investors that their principal would be kept in guaranteed accounts in a major world bank and would not be at risk. But wait, there’s more. The “investment business” claimed to operate as a tax-free church despite having had no churchlike organization, no building, no worship services, and no activities of a religious nature. The petitioner and his co-conspirators…