Question

provide facts and outcome on the Richard C. Mathews v. Commissioner tax court case

what was the ruling in the case, what was the petitioner take the commissioner to court?

the case occurred in december 2018.

Answer 1

On December 26, 2018, the Tax Court issued its opinion in Richard C. Mathews v. Commissioner, T.C. Memo 2018-212. The decision was a holiday gift to a pro se taxpayer who was contesting deficiencies (and fraud penalties) assessed well after the normal three year limitation period had expired. The IRS relied on the fraud exception in §6501(c)(1) but was unable to convince Judge Vasquez that the taxpayer had the necessary fraudulent intent. This was likely a surprising result to the IRS because the taxpayer had: (1) lied to IRS agents; (2) massively unreported gross receipts for the two years at issue and many years before that; and (3) been convicted of the §7206crime of subscribing to false tax returns for the years at issue.