Jeffery Dieffenbach

Summary

The court sustained the deficiencies, additions to tax, and accuracy-related penalties determined against petitioner for 2015 through 2019. Respondent met its burdens of production through third-party income records, account transcripts, substitutes for returns, and penalty-approval forms, while petitioner offered no evidence rebutting the determinations or substantiating deductions, losses, reasonable cause, or good faith. The court also held that the notice of deficiency was valid, the assessment period had not expired, only one examination occurred, and res judicata did not apply.