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ROGERS v. C.I.R.

Nos. 20-2789, 20-2790, 20-2791, 20-2869, 20-2870, 20-2871, 20-2872 & 20-2873.

9 F.4th 576 (2021)

Frances L. ROGERS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 17, 2021.

Attorney(s) appearing for the Case

Andrew R. Roberson , Attorney, McDermott, Will & Emery LLP, Chicago, IL, Sarah P. Hogarth , Michael B. Kimberly , Attorneys, McDermott, Will & Emery, Washington, DC, for Petitioner-Appellant.

Gilbert Steven Rothenberg , Attorney, Department of Justice, Office of the Attorney General, Carl D. Wasserman , Attorney, Department of Justice, Tax Division, Appellate Section, Ellen P. DelSole , Attorney, Department of Justice, Washington, DC, for Respondent-Appellee.

Before Bauer, Easterbrook, and Scudder, Circuit Judges.

Married since 1967, John and Frances Rogers filed joint federal income tax returns for many years. They underreported their tax obligations many times over, and the misreporting was the product of a fraudulent tax scheme designed by John, a Harvard-trained tax attorney. The fraud...

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