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Tax News
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Lessons from Hee v. Commissioner: How “Badges of Fraud” Turn a Tax Dispute into a Fraud Case
When the Tax Court issued its decision in Albert S.N. Hee and Wendy R. Hee v. Commissioner; Waimana Enterprises, Inc. v. Commissioner, T.C. Memo. 2026-53, the result was not a close call. The court sustained civil fraud penalties under Section 6663 against both Mr. Hee and his company, Waimana Enterprises, for tax years stretching back […]
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When “My Accountant Did It” Doesn’t Save You: Tax Court Slams Doctor with 75% Fraud Penalty
A new Tax Court memorandum decision, Aryanpure v. Commissioner (T.C. Memo. 2026-48), should make every business owner, especially one who handles cash, nervous. Think twice if you think your CPA firm can shield you against fraud penalties. The Setup Dr. Mohammad Fawad Aryanpure and his wife, Dr. Malika Aryanpure, were licensed physicians who jointly owned […]
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When the IRS Calls Your Ranch or Farm a Hobby: Lessons from Schumacher v. Commissioner
TC Memo. 2026-47 | June 9, 2026 A couple of veterinarians just learned a painful lesson: passion for horses, combined with years of losses and sloppy records, is a recipe for IRS disaster. In Schumacher v. Commissioner, the Tax Court upheld over $191,000 in tax deficiencies — disallowing all losses from Schumacher Quarter Horses (SQH) […]
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Tax Relief for Scam Losses
If you’ve ever worried about losing your retirement nest egg to a scammer—or if it has already happened to you or someone you love—a little-known IRS legal memo could help you recover some of your lost savings in the form of tax relief. The IRS Office of Chief Counsel recently issued guidance on a question […]
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