
Hacker v. Commissioner (T.C. Memo. 2022-16)
On March 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Hacker v. Commissioner (T.C. Memo. 2022-16). The primary issues presented in Hacker were whether the petitioners received imputed wages and constructive dividends from their day care centers and whether the petitioners were liable for the civil fraud penalty under IRC § 6663. A Note on Hacker v. Commissioner You may remember the Hackers from two Tax Court opinions from 2021,