Human Engineering Institute v. Commissioner of Internal Revenue, Joseph S. Kopas and Mary E. Kopas v. Commissioner of Internal Revenue

WISEMAN, District Judge.

Taxpayers, representing Human Engineering Institute [HEI] and themselves individually, appeal the decision of the United States Tax Court, which substantially upheld the assessment by the Commissioner of the Internal Revenue Service [IRS] of income tax deficiencies and penalties. The taxpayers also appeal the denial by the Tax Court of their motion for posttrial oral argument. To describe the history of these consolidated cases as “long and tortuous” 1 is almost an understatement at this point. The Commissioner began the audit of the individual taxpayers’ returns for…