Joseph Peery v. Comm'r of Internal Revenue

OPINION

COLE, Chief Judge.

Joseph Peery and Dawn Chapel (collectively the “Taxpayers”) appeal a decision of the United States Tax Court in favor of the Commissioner of Internal Revenue (“Commissioner”). The Tax Court held that there was a deficiency in the Taxpayers’ jointly filed 2008 tax return, and assessed an accuracy-related penalty against them pursuant to 26 U.S.C. § 6662(a). The court issued its written opinion on July 29, 2014. On August 23, 2014, the Taxpayers filed a motion for reconsideration of that opinion pursuant to Tax Court Rule 161, which the court denied on August 28. The…