On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Crim v. Commissioner (T.C. Memo. 2021-117). The primary issue presented in Crim v. Commissioner was whether the penalties assessed against the petitioner for promotion of abusive tax shelters under IRC § 6700(a) were assessed the period of limitations on assessment had expired. Author's Note: If you read nothing else, I beg you to read the Post Script, where I describe the esteemed (and in-no-way-ironical) authorship of John Michael Crim... Initial Observation in Crim v. Commissioner Although not addressed directly in the Tax Court’s opinion of Crim v. Commissioner, one has to wonder if the petitioner’s last name (Crim) was short for what he was (a convicted tax criminal).  We’re just saying…  For that matter, given Mr. Crim's weighty literary provenance, it is, perhaps, the most fortunate given nom-de-plume in history. Background to Petitioners’ Misdeeds During 1999-2003,…