Sometimes all you can do is laugh. And most likely Judge Powell, who decided today’s case, was laughing quite a bit.
The case involved taxpayers disputing the assessment of a penalty for the untimely filing of their tax return. Just one problem: the return was timely filed and the IRS did not assess such a penalty. Rather, the IRS assessed penalties for failure to pay estimated taxes and for failure to pay tax. As the judge noted, “It is sufficient to say that these are separate additions to tax for different actions.”
Case: Goldman v. Commissioner, T.C. Summary 2005-165