Not long ago, a New York City data analyst who had been laid off shortly after the pandemic hit told me she had filed for unemployment-insurance payments and then spent the next six months calling, emailing, and using social media to try to figure out why the state’s Labor Department would not send her the money she was owed.
Tax Court Finds Offshore Account Owner Not Credible; Determines Income Tax Deficiency and Civil Fraud Penalty
In Harrington v. Commissioner, T.C. Memo. 2021-95, GS here, the Court (Judge Lauber) determined deficiencies and the civil fraud penalty for a taxpayer who played the offshore account game (a pernicious variation of the audit lottery) and lost. The taxpayer was a UBS depositor; UBS disclosed the taxpayer’s information and documents. And the rest was, in a sense, inevitable. I won’t detail the particular facts of the taxpayer's audit lottery gaming, but will discuss the role of credibility.
I offer a series of excerpts directly or indirectly addressing the Court’s credibility assessments which did not go well for the taxpayer (boldface supplied by JAT except for title headings).