Morse v. Commissioner
United States Tax Court
T.C. Memo. 2003-332 (2003)
- Written by Daniel Clark, JD
Facts
Kevin Morse (plaintiff) worked part-time as a movie-theater manager. Morse also farmed several hundred acres of land, selling crops to local companies. Morse did not report the farming income to his tax preparer and filed false tax returns omitting that income. Morse was indicted and convicted for willfully filing false tax returns for four different tax years. The Internal Revenue Service (IRS) (defendant) redetermined Morse’s tax liability for those years and assessed deficiencies attributable to the unreported farming income. The IRS additionally assessed fraud penalties for those taxable years. Morse petitioned the United States Tax Court, disputing the IRS’s determinations. At the Tax Court, Morse conceded the issue of the deficiencies for underpayment but disputed the IRS’s assessment of the fraud penalties.
Rule of Law
Issue
Holding and Reasoning (Jacobs, J.)
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