Richard Essner v. Commissioner

T.C. Memo. 2020-23

UNITED STATES TAX COURT RICHARD ESSNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 7013-17, 1099-18.1 Filed February 12, 2020. Richard Essner, pro se. Mark A. Nelson and Sarah A. Herson, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: Respondent determined income tax deficiencies of $117,265 and $101,750 and accuracy-related penalties under section 6662(a)2 of 1 At trial the Court consolidated these cases for purposes of trial and opinion. 2 All section references are to the Internal Revenue Code in effect at the relevant…