- 12 - have been if he had simply filed his tax returns properly in the first place. Even if we were permitted to entertain arguments based solely in equity,6 we would not sanction petitioner’s egregious violation of the law by permitting him to avoid the consequences of his own choices; there are too many taxpayers who unintentionally run afoul of the Internal Revenue Code and yet are required to pay interest and applicable penalties to even consider relieving petitioner of liability on equitable grounds. Further, it was a condition of petitioner’s probation that he cooperate with the IRS in the collection of all outstanding taxes, interest, and penalties; we are unclear on how petitioner is able to say he has satisfied that condition when he proposes that the penalties associated with his conduct be overlooked. Petitioner is liable for the 75-percent civil fraud penalty as determined in the notice of deficiency, and no argument-- legal or equitable--persuades us otherwise. To reflect our disposition of the disputed issue, Decision will be entered for respondent. 6 “The Tax Court is a court of limited jurisdiction and lacks general equitable powers.” Commissioner v. McCoy, 484 U.S. 3, 7 (1987).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13Last modified: November 10, 2007