On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Purvis v. Commissioner (T.C. Memo. 2020-13). The issue presented in Purvis v. Commissioner was whether the IRS overcame their burden of proof to establish the petitioners’ liability for the taxes and the fraud penalty under IRC § 6663(a).  What a crazy case… The Quick and Dirty Background of One of the Craziest Cases I’ve Ever Read (Purvis v. Commissioner) This