Brian D. Beland & Denae A. Beland

CourtUnited States Tax Court
DecidedMarch 1, 2021
Docket30241-15
StatusPublished

This text of Brian D. Beland & Denae A. Beland (Brian D. Beland & Denae A. Beland) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Brian D. Beland & Denae A. Beland, (tax 2021).

Opinion

156 T.C. No. 5

UNITED STATES TAX COURT

BRIAN D. BELAND AND DENAE A. BELAND, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 30241-15. Filed March 1, 2021.

R commenced an examination of a joint return filed by Ps. A revenue agent (RA) sent Ps a summons requiring their attendance at an in-person closing conference before the end of a soon-expiring limitations period on assessment. During the closing conference the RA provided Ps a completed, signed Form 4549, Income Tax Examination Changes, reflecting an I.R.C. sec. 6663(a) civil fraud penalty. Ps declined to consent to the assessment of the civil fraud penalty reflected in Form 4549 or sign Form 872, Consent to Extend the Time to Assess Tax, to extend the limitations period. Thereafter, the RA obtained written approval from her immediate supervisor for the civil fraud penalty and sent Ps a notice of deficiency determining the same.

Ps moved for partial summary judgment contending that the civil fraud penalty was not timely approved by the RA’s supervisor as required by I.R.C. sec. 6751(b)(1).

Served 03/01/21 -2-

Held: R’s Form 4549 coupled with the context surrounding its presentation to Ps embodied the first formal communication of the RA’s “initial determination” to assess the civil fraud penalty, necessitating prior supervisory approval under I.R.C. sec. 6751(b)(1).

Held, further, Ps’ motion for partial summary judgment will be granted.

Matthew D. Carlson, for petitioners.

Sharyn M. Ortega, for respondent.

OPINION

GREAVES, Judge: This case is before the Court on petitioners’ motion for

partial summary judgment (motion). Petitioners contend that the Internal Revenue

Service (IRS or respondent) failed to secure timely written supervisory approval

under section 6751(b)(1) of a section 6663(a) fraud penalty (fraud penalty) for

petitioners’ 2011 tax year.1 For the reasons set forth below, we conclude that

respondent’s agent did not secure timely approval, and we will grant the motion.

1 Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. -3-

Background

The following facts are based on the parties’ motion papers and the attached

exhibits, unless otherwise stated, and are not disputed. Petitioners resided in

California when they filed the petition.

Respondent commenced an examination of petitioners’ 2011 Form 1040,

U.S. Individual Income Tax Return, on or shortly after October 30, 2014.

Revenue Agent Ivana Raymond (RA Raymond) met with petitioners’ certified

public accountant, Guy Black (CPA Black), in December 2014 and with CPA

Black and petitioners in January 2015. Following the December meeting, RA

Raymond and her immediate supervisor, IRS Group Manager Gabriel Pardo (GM

Pardo), referred petitioners’ case to an IRS fraud technical advisor (FTA).

Upon the request of the IRS Criminal Investigation Division and the FTA,

GM Pardo and RA Raymond issued an administrative summons to petitioners on

June 5, 2015, to appear before RA Raymond again on June 30, 2015.2 Petitioners

sent a letter to RA Raymond dated June 23, 2015, requesting a postponement of

the summons interview because petitioner wife had just given birth to petitioners’

2 The summons did not specify the purpose of the meeting but internal e-mail correspondence between respondent’s counsel and GM Pardo shows that the summons was issued at least in part “to obtain information concerning petitioners’ knowledge as to bank information and third party records.” -4-

second child. In response, respondent’s counsel sent a letter to petitioners on July

27, 2015, to compel their appearance before RA Raymond on August 19, 2015

(August meeting). The letter stated that “[l]egal proceedings may be brought

against you in the United States District Court for not complying with [the]

summons” issued on June 5, 2015. Petitioners acquiesced and appeared with CPA

Black before RA Raymond, GM Pardo, and IRS Group Manager John Yu at the

August meeting.

The August meeting constituted petitioners’ closing conference.3 During

the meeting, RA Raymond asked petitioner husband a series of prepared questions

before presenting to petitioners Form 4549, Income Tax Examination Changes,

commonly referred to as a revenue agent report (RAR),4 as well as a copy of

Publication 3498, The Examination Process. The RAR included a fraud penalty

with a stated amount and contained RA Raymond’s electronic signature. RA

3 A closing conference is held during the “closing phase of the examination” process and is meant to provide a forum for the examining agent to present the examination findings, explain proposed adjustments, and solicit agreement. See Internal Revenue Manual (IRM) pt. 4.10.7.5.1(1) (Mar. 3, 2015). 4 See IRM pt. 4.10.8.1.1 (Aug. 11, 2006) (describing an RAR as a legally binding document that serves as the basis for assessment and collection actions). The May 2008 revision of Form 4549 that RA Raymond presented to petitioners includes a place for taxpayers to sign and consent to the immediate assessment and collection of any tax and penalties shown in the form. -5-

Raymond completed the RAR before the August meeting, stating in her internal

notes that she intended to discuss the RAR during the meeting.

Petitioners declined to sign the RAR during the August meeting because

they did not agree with the fraud penalty. Petitioners also declined to sign Form

872, Consent to Extend the Time to Assess Tax, which would have extended the

limitations period on assessment for petitioners’ 2011 tax year. With fewer than

240 days left on the limitations period at the time of the August meeting, RA

Raymond informed petitioners that they would forgo their appeal rights, their 2011

examination case file would be closed, and respondent would issue a notice of

deficiency.5

On August 21, 2015, RA Raymond sent the 2011 examination case file and

Civil Penalty Approval Form containing the fraud penalty, as well as an

alternative assertion of an accuracy-related penalty pursuant to section 6662(a)

5 In general, a taxpayer may seek review of the IRS examination team’s proposed deficiency assessment by the IRS Office of Appeals (Appeals), see IRM pt. 8.1.1.3 (Apr. 4, 2014), which is now referred to as the “Independent Office of Appeals”, Taxpayer First Act, Pub. L. No. 116-25, sec. 1001, 133 Stat. at 983 (2019). The IRS issues a so-called 30-day letter, which allows the taxpayer to request Appeals consideration, only if there are at least 240 days remaining on the period of limitations. IRM pt. 4.10.8.12.1(1) and (2) (Sept. 12, 2014). If fewer than 240 days remain, the case remains unagreed, and the taxpayer does not consent to extend the limitations period, the IRS closes the case for issuance of a notice of deficiency. Id. at (3). -6-

(accuracy-related penalty), to GM Pardo for approval. GM Pardo signed the Civil

Penalty Approval Form that same day. On September 1, 2015, respondent issued a

notice of deficiency to petitioners for tax year 2011 that included the fraud penalty

without modification from the RAR given to petitioners during the August

meeting, as well as the alternative assertion of the accuracy-related penalty.

Petitioners petitioned this Court for redetermination of the deficiency and

the penalties. Thereafter, petitioners filed the motion currently before us.6

Discussion

I. Summary Judgment

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Brian D. Beland & Denae A. Beland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brian-d-beland-denae-a-beland-tax-2021.