On March 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Hacker v. Commissioner (T.C. Memo. 2022-16). The primary issues presented in Hacker were whether the petitioners received imputed wages and constructive dividends from their day care centers and whether the petitioners were liable for the civil fraud penalty under IRC § 6663. A Note on Hacker v. Commissioner You may remember the Hackers from two Tax Court opinions from 2021, Blossom Day Care Centers, Inc. v. Commissioner (Blossom I), T.C. Memo. 2021-86, and Blossom Day Care Centers, Inc. v. Commissioner (Blossom II), T.C. Memo. 2021-87. Suffice it to say, 2021 was not a good tax year for the couple, and it turns out that 2022 is not shaping up well for them, either. Procedural Background to Hacker v. Commissioner If you will recall, the IRS examined the returns of the petitioners and their day care…