Temple v. Commissioner

Robert M. Temple appeals the tax court’s denial of his petition to dismiss the Internal Revenue Service’s (IRS) notice of deficiency covering the tax years 1988 through 1992. Temple had filed no income tax returns for these years, but had worked as a veterinarian, sold exotic animals, and received oil royalties on properties on which he, his wife, and their animals resided. Temple’s defense was that all income from these sources had been *607assigned to a series of off-shore trusts and none was attributable to him. The tax court disagreed, assessed taxes and fraud penalties for the entire period…