Ashley M. Huber v. Commissioner of Internal Revenue
May 29, 2026·25-3073·Panel Decision·By Maria Santos
The United States Court of Appeals for the Eighth Circuit affirmed the Tax Court's decision sustaining a tax deficiency and penalty. The appellate court found no error in the lower court's ruling regarding the substantial understatement penalty.
Ashley Huber appealed after the Tax Court sustained the Commissioner of Internal Revenue’s calculation of her tax deficiency and penalty. This followed a trial in her action challenging a notice of deficiency.
The court’s reasoning
The court concluded that the Tax Court did not err in sustaining the notice of deficiency, including the substantial understatement penalty assessed against Huber. The court reviewed the Tax Court’s factual findings for clear error and its legal conclusions de novo.
What it means going forward
The decision upholds the IRS’s calculation of the tax deficiency and the associated penalty against the taxpayer.
