On December 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Soni v. Commissioner (T.C. Memo. 2021-137). The primary issues presented in Soni were (1) whether the petitioners filed a valid joint return; (2) whether the period of limitations for assessment of tax under IRC § 6501(a) and (c)(4) expired before the issuance of the notice of deficiency; (3) whether the petitioners are liable for an addition to tax under IRC § 6651(a)(1); and (4) whether the petitioners are liable for the 20% accuracy-related penalty under IRC § 6662(a). Background to Soni v. Commissioner The petitioners had an arranged marriage, which the court describes as “typical” and “traditional to their culture.” Petitioner-husband—whose name was Om—was a very successful businessman, and petitioner-wife was a homemaker (or “housekeeper” as the court refers to her). Petitioner-husband earned the lion’s share of the income, and petitioner-wife did not know what her…