Last night's EA Exam class was the annual Tax Court session.
In addition to outlining how Enrolled Agents work our clients Tax Court cases (yes, indeed, EAs can handle Tax Court petitions and negotiations), I pull up that day's Tax Court rulings and we analyze them in class.
Well, yesterday's rulings were just some technical adjustments, so I looked at Wednesday's decisions.
The three plaintiffs whose cases were posted on October 20, 2010 were all men.
They were all pigheaded.
And in each case, they lost because they were their own worst enemies.
Two of the cases, they were non-filer/protestor types. Their situations were typical of their genre.
Get acquainted with these people. This is the kind of behavior and attitude that you are likely to encounter. Be prepared for it - and set your fees accordingly. Or know when to decline a client.
The case of Thomas Hale was much more interesting, with respect to the balance due.
This is a perfect example of a case that should never have come to Tax Court in the first place.
That is filled with foolish behavior on the part of the taxpayer (an attorney!).
And results in the taxpayer owing nearly $100,000 in taxes, penalties and interest - that could have been avoided.
Reading these cases before class, I have to admit, I just laughed and laughed.
They are perfect for teaching. Not so much for the plaintiffs, but great for classes.
If you ever want to know exactly how to behave at audits and in Tax Court, do yourself a favor and start reading Tax Court decisions. The judges are as meticulous, polite and gracious as they can be. But sometimes they are hilarious.