On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Lufkin v. Commissioner (T.C. Memo. 2021-71). The primary issue presented in Lufkin v. Commissioner was whether the pro se petitioner was liable for certain Form 941 liabilities. Background to Lufkin v. Commissioner The IRS assessed the Form 941 liabilities, which arose in connection with the petitioner’s law practice, for the periods at issue in December 1998 and June 1999, respectively. After the