Rogers v. Commissioner

POSNER, Circuit Judge.

A trial before the Tax Court resulted in a determination that in 2003 John Rogers and his wife had failed without justification to report $984,655 of taxable income attributable to income of Portfolio Properties, Inc. (PPI), an S corporation wholly owned by Mr. Rogers, and to a distribution that he had received from PPL T.C. Memo 2011-277, 102 T.C.M. (CCH) 536 (2011). For tax purposes the income of an S Corporation is deemed the personal income of the shareholders, 26 U.S.C. § 1366, in this case the share-holder. After, the Tax Court rejected Rogers’ arguments—repeated…