Karla Amburgey & Mary Dutey-Amburgey A.K.A. Mary Amburguey

CourtUnited States Tax Court
DecidedNovember 1, 2021
Docket3339-20
StatusUnpublished

This text of Karla Amburgey & Mary Dutey-Amburgey A.K.A. Mary Amburguey (Karla Amburgey & Mary Dutey-Amburgey A.K.A. Mary Amburguey) 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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Karla Amburgey & Mary Dutey-Amburgey A.K.A. Mary Amburguey, (tax 2021).

Opinion

T.C. Memo. 2021-124

UNITED STATES TAX COURT

KARLA AMBURGEY AND MARY DUTEY-AMBURGEY a.k.a. MARY AMBURGEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 3339-20. Filed November 1, 2021.

C. Page Hamrick III, for petitioners.

Lisa P. Lafferty, for respondent.

MEMORANDUM OPINION

KERRIGAN, Judge: Respondent determined a deficiency of $15,348, an

addition to tax pursuant to section 6651(a)(1) of $1,196, and an accuracy-related

penalty pursuant to section 6662(a) of $3,070 for 2018. Unless otherwise

indicated, all section references are to the Internal Revenue Code (Code) in effect

Served 11/01/21 -2-

[*2] at all relevant times, and all Rule references are to the Tax Court Rules of

Practice and Procedure. We round all monetary amounts to the nearest dollar.

The issues for consideration are whether for 2018 petitioners are:

(1) required to repay an advance premium tax credit (APTC); (2) liable for an

addition to tax pursuant to section 6651(a)(1); and (3) liable for the accuracy-

related penalty pursuant to section 6662(a).

Background

The parties submitted this case fully stipulated, without trial, pursuant to

Rule 122. The stipulation of facts and attached exhibits are incorporated herein by

this reference. Petitioners resided in Florida when they timely filed their petition.

Petitioners, a married couple, reported an adjusted gross income of $181,183

on their joint Federal tax return for 2018. Petitioners did not receive tax-exempt

interest, nontaxable Social Security, or excluded foreign earned income during

2018, and their modified adjusted gross income was $181,183.

Petitioners obtained health insurance for 2018 through the Health Insurance

Marketplace. They were enrolled in Florida Blue HMO throughout 2018. -3-

[*3] Petitioners’ health insurance premium was $1,772 per month ($21,269 for the

year). 1

In 2018 petitioners received an APTC benefit of $1,279 per month, totaling

$15,348 for the year. The APTC was paid directly to petitioners’ insurance

company and applied to the cost of petitioners’ 2018 health insurance premiums.

On April 25, 2019, petitioners untimely filed their Form 1040, U.S.

Individual Income Tax Return, for 2018. Petitioners’ 2018 income tax return was

due April 15, 2019. Their return showed a tax liability of $12,821 for 2018. For

2018 petitioners’ household consisted of two people. Their income tax return for

2018 did not include Form 8962, Premium Tax Credit (PTC), used to reconcile the

amount of APTC a taxpayer received with the amount he or she is entitled to

receive.

On November 22, 2019, respondent issued to petitioners a notice of

deficiency with respect to their Federal income tax for 2018. Respondent

determined that petitioners were not entitled to any PTC and that they must repay

the APTC paid on their behalf in 2018. Respondent also determined an addition to

The total annual health insurance premium of $21,269 differs from the 1

product of the monthly health insurance premium multiplied by 12 months-- $21,264--due to rounding. -4-

[*4] tax for failure to file timely pursuant to section 6651 and a substantial

understatement of income tax penalty pursuant to section 6662(a) and (b)(2). The

section 6662 penalty was automatically computed through electronic means.

Discussion

Generally, the Commissioner’s determinations in a notice of deficiency are

presumed correct and the taxpayer bears the burden of proving that those

determinations are erroneous. Rule 142(a)(1); Welch v. Helvering, 290 U.S. 111,

115 (1933).

I. APTC

Petitioners do not dispute that an APTC was paid on their behalves. Rather,

they dispute that they should have to repay it. The PTC offsets the cost of health

insurance. A recipient of the PTC can choose to receive the payments in advance--

an APTC. These payments are paid directly to the insurer. See sec. 36B; McGuire

v. Commissioner, 149 T.C. 254, 260 (2017).

At the end of the year a taxpayer who received an APTC is required to

reconcile the amount of the PTC already received with the entitlement amount.

See sec. 36B(f)(2). A taxpayer reconciles these amounts by completing Form 8962

and filing it with his or her tax return. If the APTC is more than the entitlement

amount, the taxpayer owes the Government the excess APTC, and it is reflected as -5-

[*5] an increase in tax. See sec. 36B(f)(2)(A); Keel v. Commissioner, T.C. Memo.

2018-5, at *6.

A taxpayer with income greater than 400% of the Federal poverty line (FPL)

is not eligible for the PTC, meaning the full amount of the APTC received during

the tax year must be included as a tax liability on the taxpayer’s tax return. Sec.

36B(c)(1)(A), (f)(2)(B); see also sec. 1.36B-4(a)(4), Example (5), Income Tax

Regs. Household income, as relevant to petitioners, is defined as modified

adjusted gross income. See sec. 36B(d)(1) and (2)(A). Modified adjusted gross

income means gross income adjusted by certain items, including Social Security

benefits, not included in gross income. Sec. 36B(d)(2)(B)(iii).

For 2018 the FPL was $16,240 for a household of two in Florida, and 400%

of the FPL was $64,960. See 82 Fed. Reg. 8832 (Jan. 31, 2017). Petitioners

reported household income of $181,183 for 2018. Because petitioners were not

entitled to the PTC in 2018, any APTC received is excess APTC and must be

repaid to the Government. We hold that they are liable for the $15,348 deficiency.

Petitioners claim respondent cannot assess a deficiency based on excess

APTC because the “tax is void and of no effect as in violation of the Constitution

of the United States.” We disagree. -6-

[*6] In Nat’l Fed’n of Indep. Bus. v. Sebelius, 567 U.S. 519 (2012), the Supreme

Court held that the Affordable Care Act’s (ACA) penalty-backed individual shared

responsibility payment is constitutional. Petitioners argue that a subsequent

opinion, Texas v. United States, 945 F.3d 355 (5th Cir. 2019), rev’d and remanded

sub nom. California v. Texas, 593 U.S. , 141 S. Ct. 2104 (2021), renders the

individual shared responsibility payment and associated penalty invalid. We are

not persuaded.

In Texas the U.S. Court of Appeals for the Fifth Circuit dealt with 2017

amendments to the ACA that reduced the individual shared responsibility payment

under section 5000A(c) to zero. These 2017 amendments were not effective until

after December 31, 2018. Tax Cuts and Jobs Act of 2017, Pub. L. No. 115-97, sec.

11081, 131 Stat. at 2092. The deficiency at issue here stems from an increase in

tax due to excess APTC paid on petitioners’ behalves throughout 2018 before the

ACA amendments discussed in Texas took effect. Therefore, the reasoning of the

U.S. Court of Appeals for the Fifth Circuit in Texas does not apply.

On June 17, 2021, the Supreme Court vacated the judgment of the Court of

Appeals in Texas and remanded the case with instructions to dismiss. See

California v. Texas, 539 U.S. at , 141 S. Ct. at 2120. Petitioners have failed to

meet their burden of showing that the provisions of section 36B violate the -7-

[*7] Constitution. See Conard v. Commissioner, 154 T.C. 96, 103 (2020)

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Related

Welch v. Helvering
290 U.S. 111 (Supreme Court, 1933)
National Federation of Independent Business v. Sebelius
132 S. Ct. 2566 (Supreme Court, 2012)
Michelle Keel v. Commissioner
2018 T.C. Memo. 5 (U.S. Tax Court, 2018)
State of Texas v. USA
945 F.3d 355 (Fifth Circuit, 2019)

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