DeWitt Law successfully represented a taxpayer in U.S. Tax Court who had been assessed the civil fraud penalty under Internal Revenue Code § 6663—a 75% penalty imposed when the IRS alleges intentional fraud. The IRS claimed the taxpayer knowingly underreported income, seeking to add a significant penalty to an already large tax bill. However, our firm challenged the government’s claims, highlighting inconsistencies in the evidence and presenting a compelling defense grounded in both fact and law.

As a result of our representation, the IRS dropped the civil fraud penalty, and the Court entered an order removing it in full. This victory not only saved our client financially, but also protected their reputation from the damaging label of “fraud.” At DeWitt Law, we fight aggressively to ensure our clients are treated fairly—and we know how to win when the IRS overreaches.