Haury v. Commissioner

LOKEN, Circuit Judge.

Harry Haury, a software engineer, filed no federal individual income tax return for 2007. The Commissioner of Internal Revenue issued a notice of deficiency in May 2010, alleging unpaid taxes, penalties, and interest of more than $250,000 based on a substitute return prepared by the Internal Revenue Service. The deficiency asserted taxable salary income of $149,216 and taxable withdrawals from Haury’s Individual Retirement Account (“IRA”) totaling $434,964. Haury responded by petitioning the Tax Court for redetermination of the deficiency, filing a return for 2007 that…