On August 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Kidz University Inc. v. Commissioner (T.C. Memo. 2021-101). The primary issues presented in Kidz University Inc. v. Commissioner were whether the settlement officer: (1) properly verified that the requirements of applicable law or administrative procedure were met; (2) considered any relevant issues Kidz University raised; and (3) considered whether any proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of Kidz University that any collection action be no more intrusive than necessary. Initial Impressions of the Kidz University Inc. v. Commissioner How in the hell does an institution of higher learning, shaping the fragile minds of our youth, think that it’s alright to use a “z” in lieu of an apostrophe and a damn “s” to form a freaking possessive? True, it’s a daycare conglomerate, and true, it’s based in Arkansas……