Claude Douge and Jacqueline Douge v. Commissioner of Internal Revenue

CARDAMONE, Circuit Judge:

We consider on this appeal a tax court’s enforcement of a tax deficiency found by the Commissioner, and the addition of a penalty to the tax for fraud, based on its finding of a taxpayer’s intentional wrongdoing. When citizens engage in the somewhat depressing annual spring rite of preparing and filing their tax returns, they may believe, with Justice Holmes, that “[t]axes are what we pay for civilized society.” Co mpania General De Tabacos De Filipinas v. Collector of Internal Revenue, 275 U.S. 87, 100, 48 S.Ct. 100, 105, 72 L.Ed. 177 (1927) (Holmes, J., dissenting).…