Michael R. Repoli, CPA, EA

04/17/2026

I think I am back on FB. The real me. For the past several weeks my account was HACKED. To those people who received messages asking for money etc. It was NOT ME. Also they set up my name as being in Real Estate that is also FAKE. I apologize

04/17/2026

Test

03/06/2026

03/06/2026

This is a joke but it's funny

02/12/2026

·
Today’s Tax Court decision
Subject: Failure to substantively comply with the requirements necessary to determine her tax liability.
United States Tax Court
Washington, DC 20217
LOLA MARIE HUSSEY,
Petitioner v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
Docket No. 5981-24L.
Served 02-11-2026
1. Facts:
Lola Marie Hussey was a nurse anesthetist who provided services as an independent contractor and received substantial compensation from various employers from 2015 to 2019. Despite earning this income, she filed tax returns for these years reporting $0 income. The IRS, upon reviewing her filings, assessed penalties under section 6702 for failing to report her income accurately. Hussey did not appear at trial, did not submit a pretrial memorandum, and contested the penalties without evidence during the administrative hearing, asserting that the IRS did not follow proper procedures.
2. Issue:
The primary legal issue is whether the IRS properly assessed penalties against Hussey under section 6702(a) for filing income tax returns that did not substantially reflect her actual income, and whether the procedures followed by the IRS in making that determination were compliant with the required legal standards.
3. Rules:
United States Tax Court Rules:
Rule 152(b): Allows for oral findings of fact and opinion by the Tax Court, which cannot be cited as authority except as provided by Rule 152(c).
Rule 152(c): Establishes that bench opinions cannot be cited for precedential value but are directly relevant in the context of the case.
Internal Revenue Code (IRC) Sections:
Section 6702: Imposes penalties on individuals filing returns that do not contain sufficient information to determine tax liability and reflect a desire to delay or impede tax law administration.
Section 6751(b): Requires that penalties assessed by the IRS have supervisory approval to ensure procedural compliance.
Sections 6320 and 6330: Governs the rights of a taxpayer to a hearing and procedural requirements that the IRS must follow before collections can be enforced.
Major Cases Referenced:
Magana v. Commissioner, 118 T.C. 488 (2002): In this case, the Tax Court affirmed that the IRS must adhere to procedural requirements when making determinations related to tax liabilities.
4. Application:
The rules and code sections apply directly to Hussey's situation. By filing tax returns that reported $0 income, Hussey's filings are characterized under section 6702 as lacking information necessary for the IRS to assess her tax liability accurately. The court found that the IRS had adequately shown that her conduct indicated an intentional effort to delay compliance with tax obligations. Furthermore, the IRS complied with procedural requirements outlined in sections 6320 and 6330, as demonstrated by maintaining a valid administrative hearing process, despite Hussey's failure to participate fully. The court recognized that penalties can only be assessed after proper compliance with section 6751(b), which was met in this case.
5. Conclusion:
The Tax Court concluded that the IRS correctly assessed the penalties against Lola Marie Hussey for the tax years in question, as her returns did not substantively comply with the requirements necessary to determine her tax liability. The court upheld the IRS's actions due to appropriate procedural compliance and Hussey's lack of evidence to argue otherwise. Thus, the decision favored the IRS, allowing for the collection of taxes as stipulated in their Notices

01/27/2026

Date: Jan. 22, 2026

Contact: [email protected]

Newark, NJ – A Passaic County man was sentenced to 144 months’ imprisonment for his role as a member of a drug trafficking organization responsible for the importation and distribution of hundreds of kilograms of fentanyl analogues, Senior Counsel Philip Lamparello announced.

Defendant William Panzera of North Haledon, New Jersey was previously convicted of drug trafficking conspiracy and international promotional money laundering conspiracy by a jury in Newark, New Jersey. U.S. District Judge Susan D. Wigenton imposed the sentence today in Newark federal court. Eight other defendants have previously pleaded guilty in the case and are awaiting sentencing.

According to documents filed in this case and statements made in court:

From approximately January 2014 through September 2020, William Panzera and other members of the drug trafficking organization agreed to import and distribute various controlled substances and controlled substance analogues, including fentanyl analogues, M**A, methylone, and ketamine. Members of the conspiracy placed orders with a source in China and agreed to distribute, and did distribute, the controlled substances and analogues in New Jersey, both in bulk and in the form of counterfeit pharmaceutical pills that actually contained fentanyl analogues. In total, they imported over a metric ton of fentanyl related substances and other drugs into the United States. They also sent hundreds of thousands of dollars to China using wire transfers and Bitcoin to pay for the drugs.

In addition to the prison term, Judge Wigenton sentenced Panzera to 5 years of supervised release.

Senior Counsel Philip Lamparello of the New Jersey U.S. Attorney’s Office and Assistant Attorney General A. Tysen Duva of the Justice Department’s Criminal Division made the announcement. Senior Counsel Lamparello credited special agents of Homeland Security Investigations (“HSI”) – Newark, under the direction of Special Agent in Charge Michael S. McCarthy, with the investigation leading to today’s guilty plea. He also thanked U.S. Customs and Border Protection in New Jersey, New York, and Kentucky, HSI in Philadelphia, the Federal Bureau of Investigation – Newark Division, U.S. Postal Inspection Service in Newark, IRS-Criminal Investigation, the Newark Police Department, and the Essex County Prosecutor’s Office for their assistance.

The government is represented by Assistant U.S. Attorney Sammi Malek and Special Assistant U.S. Attorney Alexander Hasapidis-Sferra of the Criminal Division in Newark and Trial Attorney Stephen Sola, Chief of the Money Laundering and Forfeiture Unit of the Justice Department’s Money Laundering and Asset Recovery Section. Financial Investigator Kathryn Montemorra of the MLARS Special Financial Investigations Unit supported the investigation. The case is being prosecuted jointly by the United States Attorney’s Office, District of New Jersey and the Money Laundering and Asset Recovery Section (MLARS) of the United States Department of Justice.

IRS Criminal Investigation (IRS-CI) is the law enforcement arm of the IRS, responsible for conducting financial crime investigations, including tax fraud, narcotics trafficking, money laundering, public corruption, healthcare fraud, identity theft and more. IRS-CI special agents are the only federal law enforcement agents with investigative jurisdiction over violations of the Internal Revenue Code, obtaining a 90% federal conviction rate. The agency has 19 field offices located across the U.S. and 14 attaché posts abroad.

01/16/2026

The start of the 2026 filing season is almost here!
The IRS will begin accepting individual tax returns on Jan. 26, 2026. The agency is expecting more than 164 million returns to be filed electronically this year. Taxpayers can file their returns and pay any tax due until April 15, 2026, without incurring penalties.
Beginning Jan. 13, 2026, at 9 a.m. Eastern Time, the IRS will begin accepting business returns through the Modernized e-File system (MeF). Additional business returns will become available for MeF beginning Jan. 18, 2026, including Forms 1042, 1120-H, 709, 709-NA and 1041. Return transmitters and authorized IRS e-file providers should monitor the MeF Status page for updates and system availability.

01/01/2026

Crazyness

01/01/2026

Worth the read. I needed this.

On the first morning of school, a fifth grade teacher stood in front of her class and said what most teachers say. That she loved all her students the same.
It was not true.
Sitting in the front row was a boy named Teddy Stoddard. He slouched in his chair. His clothes were often dirty. His hair looked like it had never met a comb. He did not mix well with other children. Some days, he barely spoke at all.
The teacher had noticed him the year before. Teddy seemed distant. Sometimes rude. Sometimes lost in his own world. Before long, irritation turned into quiet resentment. When she graded his papers, she pressed her red pen hard. Big X marks. A bold F at the top. Part of her felt satisfied doing it.
Every teacher was required to read student records. She saved Teddy’s for last.
When she finally opened his file, her stomach dropped.
First grade said Teddy was bright, polite, and a joy to be around.
Second grade said he was doing well but his mother was dying and home life was heavy.
Third grade said his mother had passed away. Teddy was trying, but his father was distant. Trouble was coming if nothing changed.
Fourth grade said Teddy had become withdrawn. He had few friends. He sometimes slept in class.
Shame hit her hard.
A few weeks later, Christmas arrived. Students brought gifts wrapped in shiny paper and bows. Teddy brought one wrapped in a brown grocery bag. When she opened it, some children laughed. Inside was a rhinestone bracelet with stones missing and a small bottle of perfume that was almost empty.
She stopped the laughter. She slipped the bracelet onto her wrist and dabbed the perfume on her skin, praising the gift.
After school that day, Teddy stayed behind.
He looked at her and said quietly, Mrs. Thompson, today you smelled just like my mom used to.
That night, she cried for a long time.
From that day on, she stopped teaching lessons and started teaching children.
She gave Teddy her time. Her patience. Her belief.
Something woke up inside him.
By the end of the year, Teddy was one of the strongest students in the class.
Years passed.
A note came. Teddy said she was the best teacher he had ever had.
Another letter arrived years later. He had finished high school near the top of his class.
Then another. College graduation. Highest honors.
Then another. He had gone even further. He signed his name Theodore F. Stoddard, MD.
One last letter came before his wedding. He asked if she would sit where the groom’s mother would normally sit. His mother was gone. His father too.
She said yes.
She wore the bracelet. Missing stones and all. She wore the perfume.
When they hugged, he whispered, Thank you for believing in me. Thank you for making me feel like I mattered.
She whispered back through tears. You are wrong, Teddy. You are the one who taught me.
This story has been shared for decades because it reminds us of something easy to forget.
One kind moment can change the direction of a life.
One person who chooses to see instead of judge can rewrite a future.
If you are reading this today, remember someone once needed patience from you. Or maybe still does.
Do not underestimate what kindness can do.

12/21/2025

oh so true

12/21/2025