Paul L. Thomas v. Commissioner of the Internal Revenue Service

Affirmed by published opinion. Chief Judge ERVIN wrote the opinion, in which Judge WILKINSON and Judge WILKINS joined.

OPINION

ERVIN, Chief Judge:

This is an appeal from a decision of the tax court holding petitioner, Paul Thomas, civilly liable for deficiencies in income tax payments for the years 1983, 1984, and 1986, as well as for additions to the tax as a consequence of Thomas’ civil fraud. While not disputing his liability for the tax deficiencies, Thomas argues that imposing an addition to tax under I.R.C. § 6653(b)(1) violates the double jeopardy protection against multiple punishments…