On August 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Babu v. Commissioner (T.C. Memo. 2020-121). The sole issue before the court in Babu v. Commissioner was whether the petitioner was liable for the substantial understatement accuracy-related penalty under IRC § 6662(a), IRC § 6662(b)(2), IRC § 6662(d)(2). Background to Babu v. Commissioner After earning a B.A. degree in finance, Mr. Babu attended law school at the University of Baltimore,