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