Penalties Under the Code
Crazy Germans

Frivolous Taxpayers and the Jurists who Loathe Them

Frivolous taxpayers are amongst my absolute favorites.  The opinions that they spawn are just wonderful breaks in an otherwise monotonous string of upheld determinations…especially when they involve crazy German nationals, as no less than three did in 2020.  In this article, we examine the frivolous return penalty (IRC § 6702) and the frivolous petition penalty (IRC § 6673(a)(1)).  In doing so, we include a discussion of some of the taxpayers that made 2020 so much

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Scott St. Amand April 15, 2021
Penalties Under the Code
Abuse of Discretion

Smith v. Commissioner
T.C. Memo. 2021-29

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smith v. Commissioner (T.C. Memo. 2021-29). The primary issues presented in Smith v. Commissioner were whether a photocopy of an original purported return, for which the IRS has no record and on which the petitioner expects the IRS to act in making a refund, purports to be a return of income tax, and whether the petitioner was liable for the

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Scott St. Amand March 10, 2021
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Frivolous Taxpayers and the Jurists who Loathe Them

Frivolous taxpayers are amongst my absolute favorites.  The opinions that they spawn are just wonderful breaks in an otherwise monotonous string of upheld determinations…especially when they involve crazy German nationals, as no less than three did in 2020.  In this article, we examine the frivolous return penalty (IRC § 6702)

Read More »
Scott St. Amand April 15, 2021

Smith v. Commissioner
T.C. Memo. 2021-29

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smith v. Commissioner (T.C. Memo. 2021-29). The primary issues presented in Smith v. Commissioner were whether a photocopy of an original purported return, for which the IRS has no record and on which the petitioner

Read More »
Scott St. Amand March 10, 2021