Tucker v. United States

OPINION

REGINALD W. GIBSON, Judge:

This individual income tax refund suit stems from a Notice of Jeopardy Assessment and Right of Appeal issued on May 4, 1981, by the District Director of Internal Revenue, Oklahoma City, Oklahoma, to plaintiff herein, Clinton David Tucker, for unpaid income taxes, penalties, and interest for the calendar years 1979 and 1980 in the total amount of $272,147.97.1 The civil fraud penalties were imposed by the District Director pursuant to 26 U.S.C. § 6653(b) upon his determination that there was probative evidence to the effect that Mr. Tucker intended to…