Whether the IRS has proved by clear and convincing evidence that Henry J. Langer and Patricia K. Langer are liable for fraud penalties for tax years 2011-2013

Question(s) Presented For Review Henry J. Langer and Patricia K. Langer (taxpayers) appealed the decision of the United States Tax Court which states “that the judgment _ of the tax court in this cause is affirmed in accordance with the opinion of this Court”. 1. Whether Respondent has proved by clear and convincing evidence that Henry J. Langer is liable for the fraud penalty for the years 2011, 2012, and 2013? 2. Whether Respondent has proved by clear and convincing evidence that Patricia K. Langer is liable for the fraud penalty for the years 2011, 2012, and 2013? : i