In Uncategorized on 09/28/2021 at 17:20

Judge Buch has the reputation of being taciturn, not given to loquaciousness. Not abrupt, of course, courteous, but direct.

Today he demonstrates that many words are unnecessary when facts speak for themselves. Here’s Robert S. Clark, 2021 T.C. Memo. 114, filed 9/28/21

” In… the years at issue, Robert S. Clark owned an auto body shop, rental properties, a large home, and numerous trucks, automobiles, and utility vehicles. His ability to acquire these assets is a remarkable feat given that, according to his tax returns, he had taxable income of $114, $0, $0, and $0, respectively, during those years. Or he fraudulently underreported his income. The Commissioner established by clear and convincing evidence that he fraudulently underreported his income.” 2021 T. C. Memo. 114, at pp. 1-2.


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