Irwin Schiff v. Commissioner of Internal Revenue

Irwin Schiff appeals from an order of the United States Tax Court (Hamblen, J.) which dismissed his petition for redetermi-nation of income tax deficiencies for the years 1974 and 1975 and upheld the Commissioner’s assessment of additions to tax for failure to pay estimated tax, 26 U.S.C. § 6654, and fraudulent underpayment, id. § 6653(b).

Appellant essentially urges this Court to reverse the decision of the tax court because it did not accept his arguments that he could not be penalized for fraudulent underpayment of taxes when he, in fact, made no payment, that the tax on wage income is…