On June 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Ervin v. Commissioner (T.C. Memo. 2021-75). The primary issue presented in Ervin v. Commissioner was whether the petitioner’s criminal restitution payments satisfied his income tax liability. Background to Ervin v. Commissioner This may be a rather vast generalization, but most folks named Monty are not the most trustworthy.  Monty Ervin is one such Monty.  Monty failed to file Federal income