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Kramer v. Comm’r, T.C. Memo. 2021-16 | February 16, 2021 | Gale, J. | Dkt. Nos. 15224-17 & 15368-17
Short Summary: The IRS issued two notices of deficiency to Don Kramer and Lela Arabuli (petitoners). The first notice of deficiency asserted deficiencies for petitioners’ 2006-2010 tax years and various penalties fraud penalties were asserted solely against Don Kramer for 2006-2008. The second notice of deficiency determined related solely to Don Kramer and asserted, among other things, fraud penalties for his 2004-2005 tax years. Petitoners timely filed a petition with the United States Tax Court to challenge the IRS’ determinations. However, petitioners failed to respond to the IRS’ discovery requests, including request for admissions. In reply to the IRS’ discovery requests, don Kramer filed a document entitled “Tax Statement Affidavit,” which set forth hundreds of pages of tax-protestor rhetoric. Lela Arabuli did not respond at all. Accordingly, after motion by the I