Legal Opinion

Carreon v. Comm'r

United States Tax Court

Decided January 9, 2014No. Docket Nos. 22720-11, 22729-11, 22747-11, 22871-11UnpublishedCited by 2 opinions

R determined that Ps were engaged in a civil fraud scheme and liable for the I.R.C. sec. 6663 75% civil fraud penalty for the tax years at issue. Held: R did not prove by clear and convincing evidence that Ps' underpayments were attributable to fraud. Accordingly, Ps are not liable for the I.R.C. sec. 6663 civil fraud penalty.

1Opinion of the Court

DAVID L. CARREON, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Carreon v. Comm'r

Docket Nos. 22720-11, 22729-11, 22747-11, 22871-11

United States Tax Court

T.C. Memo 2014-6; 2014 Tax Ct. Memo LEXIS 6; 107 T.C.M. (CCH) 1040;

January 9, 2014, Filed

Decisions will be entered under Rule 155.

R determined that Ps were engaged in a civil fraud scheme and liable for the I.R.C. sec. 6663 75% civil fraud penalty for the tax years at issue.

Held: R did not prove by clear and convincing evidence that Ps' underpayments were attributable to fraud. Accordingly, Ps are not liable for the…

2Cases cited18 opinions

  1. United States v. BoyleSupreme Court of the United States · 1985
  2. Otsuki v. CommissionerUnited States Tax Court · 1969
  3. Chris D. Stoltzfus and Irma H. Stoltzfus v. United StatesCourt of Appeals for the Third Circuit · 1968
  4. Grosshandler v. CommissionerUnited States Tax Court · 1980
  5. Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986

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3Cited by2 opinions

  1. In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
  2. Patrick Combs v. CommissionerUnited States Tax Court · 2019

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