On February 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Slone v. Commissioner (T.C. Memo. 2022-6). The primary issues presented in Slone were (i) whether the IRS bore the burden of production to show timely supervisory approval of the accuracy-related penalty; (ii) whether the IRS was entitled to maintain claims against the petitioners and the trusts at issue. Editor's Note to Slone v. Commissioner The contempt that Judge Lauber (appropriately) has for the Ninth Circuit Court of Appeals is palpable in this opinion. As you can see from this history of this case, the Tax Court and the Ninth Circuit had a veritable measuring contest, and, sadly, the Ninth Circuit won (most of) the day. Because, you know, Article I supremacy. That doesn't mean Albert Lauber is going to take it without a few jabs, though. Kudos, Judge Lauber. Stick it to the hippies. Case…