David E. Heasley and Kathleen Heasley v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• “[The Heasleys] do not dispute the tax deficiency but instead challenge the ... assessment of penalties.”
• “In other words, the [plaintiffs’] valuation overstatement does not change the amount of tax actually owed.”
• “Whenever the I.R.S. totally disallows a deduction or credit, the I.R.S. may not penal- ize the taxpayer for a valuation overstatement included in that deduction or credit.”
• “Certainly, their failure to outguess their financial advisor and accountant is not negligence.”

Source: CourtListener parenthetical corpus (CC0).