On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Koh v. Commissioner (T.C. Memo. 2020-77). The issue before the court in Koh v. Commissioner was whether Counsel for the IRS may make an initial determination for purposes of satisfying IRC § 6751(b)(1). Personal Note I was ready to write this case off. It is only six pages long, and so imagine how pleased I was to see an actual