Lon B. Isaacson v. Commissioner

T.C. Memo. 2020-17

UNITED STATES TAX COURT LON B. ISAACSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 29484-14. Filed January 23, 2020. Joseph A. Broyles, for petitioner. Cassidy B. Collins, Andrea M. Faldermeyer, Christine A. Fukushima, and Priscilla A. Parrett, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: Petitioner seeks redetermination of his income tax liability for tax year 2007. Respondent determined a deficiency of $2,583,374 and -2- [*2] a civil fraud penalty of $1,937,531 under section 6663.1 After concessions,2 the remaining issues…