On September 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Patel v. Commissioner (T.C. Memo. 2020-133). The primary issue before the court in Patel v. Commissioner was whether the IRS secured timely prior written supervisory approval for the penalties at issue as required by IRC § 6751(b)(1). The (Purported) Background in Patel v. Commissioner I enter this case with a fair bit of skepticism, due in toto to Judge Jones’ use of the word “purported” in two of the first three sentences.  This reminds me a bit too much of a criminal defense attorney interjecting “allegedly” when the prosecutor is saying that his clients stole a bag of cash from a bank, the ink stains and powder burns still remaining on the defendant’s hands from the exploding dye pack being Exhibit A of said theft.  Sorry…”alleged” theft. Allegedly, the petitioner-husband was an ophthalmologist and sole…