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 ...