Legal Opinion
Jesus R. Oropeza v. Commissioner
United States Tax Court
Decided October 13, 2020No. 15309-15Published
1Opinion of the Court
155 T.C. No. 9
UNITED STATES TAX COURT JESUS R. OROPEZA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15309-15. Filed October 13, 2020. R opened an examination of P’s 2011 tax year. On January 14, 2015, facing an expiring period of limitations, the revenue agent (RA) sent P a Letter 5153 and accompanying report (RAR). The RAR as- serted a 20% accuracy-related penalty “attributable to one or more of” negligence, a substantial understatement of income tax, a substantial valuation misstatement, and a “transaction lacking economic sub- stance.” See I.R.C. sec. 6662(a),…
2Cases cited5 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
- Chai v. CommissionerCourt of Appeals for the Second Circuit · 2017
- Estate of Scott C. Ronning, Harlan L. Paul, Personal Representative v. CommissionerUnited States Tax Court · 2019