100 dollars behind puzzle peices

Fortune smiled on Robert S. Clark: He had “an auto body shop, rental properties, a large home, and numerous trucks, automobiles, and utility vehicles.” Clark v. Comm’r,  T.C. Memo 2021-114, 2021 Tax Ct. Memo LEXIS 148 at **1 (Sept. 28, 2021). Between 2011 and 2014, Mr. Clark filed income tax returns declaring the following amounts of income:

  • 2011- $114.00;
  • 2012- $0.00;
  • 2013- $0.00; and
  • 2014- $0.00.

While that could be a run of bad luck, the IRS didn’t think so. In 2013, it began an examination of the 2011 tax return that Mr. Clark filed with his wife.

Mr. Clark and his wife met the revenue agent on September 25, 2013; during the interview, they stated that their only income came from the body shop even though Mr.… Read More