William Rogers v. Commissioner, IRS

EDWARDS, Senior Circuit Judge:

This case involves an appeal -by Yen-Ling Rogers (“Rogers”) and her husband William Rogers (together, “Appellants”) challenging a decision of the Tax Court denying their request to redetermine their tax liability for 2007 and imposing a 20% penalty for negligently failing to follow the tax rules.

The United States income tax system reaches all U.S. citizens’ income no matter where in the world it is earned, “unless it is expressly excepted by another provision in the Tax Code.” See Comm’r v. Schleier, 515 U.S. 323, 328, 115 S.Ct. 2159, 132 L.Ed.2d 294 (1995); see…