On July 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Dennis v. Commissioner (T.C. Memo. 2020-98). The primary issue before the court in Dennis v. Commissioner was whether the petitioners were entitled to reasonable litigation or administrative costs when, after CDP appeals, petition, and remand from Tax Court to Appeals, the IRS conceded all issues. Brief Background in Dennis v. Commissioner The IRS screwed this one up, but they were