On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Morris v. Commissioner (T.C. Memo. 2021-120). The primary issue presented in Morris v. Commissioner was whether the petitioner’s or liable for penalties for failure to timely file (IRC § 6651(a)(1)), failure to timely pay (IRC § 6651(a)(2)), and failure to pay estimated tax (IRC § 6654). Held: Yes. Yes, they were. Background to Morris v. Commissioner Mr. Morris was a