The United States Tax Court recently ruled against Anthony J. Moiseshyn and Mai Moiseshyn in a case concerning unreported income for the tax year 2021. The court found that the couple failed to report significant capital gains, dividends, and interest income, leading to a tax deficiency of $7,295. This ruling is important as it underscores the responsibilities taxpayers have in accurately reporting their income to the Internal Revenue Service (IRS).

The case, docket number 6587-24, was filed on November 4, 2026. The Moiseshyns, who represented themselves in court, contested the IRS's determination that they had unreported income. The ruling has implications for taxpayers who might be unaware of their reporting obligations, especially concerning income derived from employee stock purchase plans.

In this case, the Moiseshyns were facing a Notice of Deficiency issued by the IRS, which claimed they did not report capital gains from the sale of stock, along with dividend and interest income. The IRS determined that the couple owed taxes on unreported income totaling $43,800, which included $42,309 from the sale of securities, $1,345 in dividends, and $146 in interest. The couple's tax preparer had believed that all relevant income was included in the wages reported on their Form W-2, leading them to not report the stock sale.

The Moiseshyns resided in California at the time of the filing and had hired a tax return preparer to assist with their 2021 joint tax return. Their primary source of income was from Anthony's employment with Medtronic PLC, where he worked as a sales representative until his retirement in 2025. Through his employment, he participated in the Medtronic Employee Stock Purchase Plan (ESPP), which allowed him to purchase company stock at a discount. The couple claimed that their tax preparer had indicated that the income from the stock sale was already accounted for in their reported wages, which contributed to their decision not to report it.

During the trial, the court examined the evidence presented, including Forms 1099-B, which reported the gains from the stock sale, as well as Forms 1099-DIV and 1099-INT, which documented the dividends and interest income. The IRS provided substantial evidence linking the couple to the unreported income, including the tax forms that showed the amounts they failed to report. The court noted that the Moiseshyns did not challenge the accuracy of the forms provided by the IRS, which established a clear connection between the couple and the income-producing activities.

Judge Fung presided over the case and emphasized that the IRS's determinations in a Notice of Deficiency are generally presumed correct, placing the burden of proof on the taxpayer to show that the determinations are erroneous. The court ultimately ruled in favor of the IRS, concluding that the couple owed taxes on the unreported income. The court stated, "We are not convinced that the gain from the disposition of Mr. Moiseshyn’s Medtronic ESPP stock was included in the wages reported on his 2021 Form W–2." This ruling highlights the importance of accurate income reporting and the responsibilities of taxpayers to ensure all income is disclosed.

The court's decision means that the Moiseshyns will be liable for the tax deficiency of $7,295, which includes the unreported securities income of $32,146.74, dividend income of $1,345, and interest income of $146. The IRS had initially conceded a portion of the penalties, but the couple remains responsible for the remaining tax obligation.

This ruling serves as a reminder to taxpayers about the importance of understanding their tax reporting responsibilities. It also underscores the potential consequences of failing to report income accurately, which can lead to significant tax liabilities. Taxpayers should be aware that income derived from various sources, including stock sales and dividends, must be reported to the IRS, regardless of whether they believe it has already been accounted for in other forms.

Moving forward, the Moiseshyns may consider appealing the court's decision, although details about any potential appeal were not mentioned in the court filing. The ruling may also influence other taxpayers who find themselves in similar situations, emphasizing the need for diligence in tax reporting and compliance.