Schussel v. Commissioner of Revenue

Since the 1970s, George and Sandra Schussel 2 have owned property and business interests in Massachusetts, and have had other close ties to the Commonwealth. The Schussels, who are married, filed no Massachusetts tax returns between 1989 and 2007. In 2007, George was convicted of Federal conspiracy and tax evasion charges in the United States District Court for the District of Massachusetts. The Commissioner of Revenue (commissioner) then issued the Schussels a notice of failure to file Massachusetts income tax returns for the years 1993, 1994, and 1995. When the Schussels subsequently filed…