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Tax Court Calls the Bluff of a Savvy Taxpayer
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Subscribe09 SEP 2026 / ACCOUNTING & TAXES
Tax expert Peter J. Janangelo Jr. has been penalised by the Tax Court for knowingly misusing tax rules to make aggressive deductions on his returns. His background as an IRS revenue agent, attorney, and CPA led the court to deem his actions as deliberate fraud rather than inadvertent negligence, resulting in a 75% civil fraud penalty, and serves as a warning that tax professionals are held to higher scrutiny in their personal filings.
What happens when an IRS revenue agent, attorney, and CPA tries to game the tax code on his own return? The Tax Court’s answer in Janangelo Jr. v. Commissioner is blunt: you don’t get slack for knowing the rules; you get hit harder.In a 32-page summary op...
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