On January 7, 2020, the Tax Court issued its opinion in Frost v. Commissioner (154 T.C. No. 2). The issue presented in Frost v. Commissioner was whether the IRS satisfied the burden of production under IRC § 7491(c) in offering evidence of compliance with the requirement of IRC § 6751(b)(1) that the agent initially determining accuracy-related penalties obtained timely written supervisory approval to assert IRC § 6662(a) accuracy-related penalties against the petitioner. Parsing the Semantics in Frost v. Commissioner: Burden of Proof and Burden of Production A burden is a burden, right? When you’re thirty-three, living in your mother’s basement in the ‘burbs, with a Cheeto-stained, ironical (your word, not mine) hipster mustache, then yes. That’s a burden, no matter how you slice it. No need to prove it or to produce evidence to support it. You’re a bum and a burden. Shave the flavor saver, and get a damn…