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Andrew Filipowski v. Commissioner of Internal Revenue · редакция 1 → 2 · зафиксировано 2026-09-17 03:09 · +1 −1 строк

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## FOR PUBLICATION

In February 2018, the IRS issued a notice of deficiency stating that Filipowski could not claim $110 million in losses from the tax shelter, owed $32.5 million in tax liability, and was liable for an

1See New Millennium Trading, LLC v. Comm’r, No. 06-tc-3439, 2017 WL 89130, at *13–14 (T.C. Jan. 10, 2017).

1 See New Millennium Trading, LLC v. Comm’r, No. 06-tc-3439, 2017 WL 89130, at *13–14 (T.C. Jan. 10, 2017).

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25-11382 Opinion of the Court additional $13 million in accuracy-related penalties and $65.6 million in statutory interest. Filipowski did not challenge the notice of deficiency or the calculated tax liability. Besides applying about $21,000 in tax credits accrued from previous tax years to the amount owed, Filipowski did not make any payments towards the assessed liability.

AFFIRMED.