Pridgen v. Internal Revenue

OPINION

In 1987, Mark D. Pridgen and Dewey R. Gaskins (“the taxpayers”), along with Harry Lee Roberts, 1 formed Beaufort Leaf Tobacco Company, a North Carolina general partnership, for the principal purpose of buying and selling tobacco; they contin ued in business until 1992. In this appeal, we are called upon to decide whether the United States Tax Court erred in finding the taxpayers liable for deficiencies, interest, and penalties due on their 1990 and 1991 federal income tax returns because Beaufort Leaf failed to report all of its income from sales of tobacco and failed to substantiate…