Anna Elise Walton, 2021 T. C. Memo. 40, filed 3/30/21, “skimmed over a copy of her return after filing and thought that the totals were correct.” 2021 T. C. Memo. 40, filed 3/30/21, at p. 7.
Unhappily, AE didn’t do enough, says Judge Patrick J (“Scholar Pat”) Urda, despite the efforts of Frantic Frank Agostino and The Jersey Boys. The Jersey Boys lose a lot of cases, because they get the real tough ones; I very much doubt anyone could do better. I was once an attorney in a firm where we lost a lot of cases, because we took a lot of the toughest cases.
AE concedes her return missed about 32% of her taxable income for the year in question. And even though her trusty CPAs, to whom she’d entrusted her taxes for twenty (count ’em, twenty) years, may have failed to press her for the missing 1099-MISCs, which triggered the AUR and electroSNOD that followed, size does matter. When you know you made money (and AE did), and your reported AGI swings lower than a sweet chariot, you won’t get Section 6664(a) good faithery. That’s all AE could try for this time.
The AUR and electroSNOD defeat Section 6751(b). No Boss Hoss needed when the computer does it all.
Takeaway- Read and heed…your return, if not my blogposts.
Taishoff Law 
Thank you for the kind words. We are honored to help unrepresented taxpayers get their day in Court. Hope to see you at a training session for the volunteers that assist NY/NJ low income and multicultural taxpayers. – Frank Agostino – aka one of the Jersey Boys.
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Frank, you played well out of a tough lie. I’ve taken your courses and found them valuable. No easy junk CPE/CLE hours from you. And you gave us Graev, the gift that keeps on giving.
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