Philip T. and Mary Ellen Chaplin - Page 28

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               hardship, but challenges based on equity have been                     
               uniformly rejected. * * *                                              
                    * * * it “is not a feasible judicial undertaking                  
               to achieve global equity in taxation * * *.  And if it                 
               were a feasible judicial undertaking, it still would                   
               not be a proper one, equity in taxation being a                        
               political rather than a jural concept.” * * * the                      
               solution must be with Congress.                                        
          Speltz v. Commissioner, 124 T.C. 165, 176 (2005) (quoting Kenseth           
          v. Commissioner, 259 F.3d 881, 885 (7th Cir. 2001), affg. 114               
          T.C. 399 (2000)), affd. 454 F.3d 782 (8th Cir. 2006); see also              
          Alexander v. IRS, 72 F.3d 938 (1st Cir. 1995); Okin v.                      
          Commissioner, 808 F.2d 1338 (9th Cir. 1987), affg. T.C. Memo.               
          1985-199; Warfield v. Commissioner, 84 T.C. 179 (1985);                     
          Huntsberry v. Commissioner, 83 T.C. 742, 747-753 (1984).                    
          Petitioners’ equity argument offers no relief from the accuracy-            
          related penalty.                                                            
               For the above-stated reasons, we find petitioners are liable           
          for an accuracy-related penalty under section 6662(a) of $4,837.            
               In reaching our holdings, we have considered all arguments             
          made, and, to the extent not mentioned, we conclude that they are           
          moot, irrelevant, or without merit.                                         
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          








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