Schussel v. Commissioner of Revenue

This is an appeal from an Appellate Tax Board (board) decision upholding the denial by the Commissioner of Revenue (commissioner) of a request for an abatement of double taxes assessed to George and Sandra Schussel (Schussels) for filing false or fraudulent income tax returns for the calendar years 1993, 1994, and 1995 (tax years at issue). The case presents three issues: first, whether the board erred as a matter of law in upholding the commissioner’s double tax assessment based on the Schussels’ false or fraudulent filings; second, whether the Schussels were entitled to amnesty from the…