Prosser v. Commissioner

DRONEY, Circuit Judge:

Robert and Mary Prosser (“the Prossers”) and the McGehee Family Clinic (“the Clinic,” and collectively “Petitioners”) filed petitions for redetermination in the United States Tax Court challenging the Commissioner of Internal Revenue’s (“Commissioner”) determination of tax deficiencies and assessment of penalties against them under § 6662A of the Internal Revenue Code, 26 U.S.C. § 1 et seq. (“I.R.C.”). The Commissioner had determined that Petitioners were deficient based on a contribution by the Clinic to a multiple-employer welfare benefit plan, the Benistar 419 Plan…