John L. Stephenson v. Commissioner of Internal Revenue

The Tax Court in this case assessed Civil fraud penalties under I.R.C. § 6653(b) for the tax years 1976 and 1977, and also assessed penalties for underpayments of estimated tax under I.R.C. § 6654 for the latter tax year, against John Lynn Stephenson, a physician, of Chelsea, Michigan. See Stephenson v. Commissioner, 79 T.C. 995 (1982). Stephenson worked as a physician employee of the Allegan Medical Clinic, P.C. (the “Clinic”), and was paid wages of $50,692 in 1976 and $32,302 in 1977; he worked also as a physician rendering services to the Chelsea Emergency Physicians, P.C. (“CEP”) in 1977…