On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Mason v. Commissioner (T.C. Memo. 2021-64). The primary issue presented in Mason was whether Appeals abused its discretion by reviewing the Centralized Unit’s decision for abuse of discretion instead of reviewing the Masons’ offer on its merits. Background: A Lesson in Bureaucracy Victor and Katherine Mason owed back taxes. They didn’t deny it, but they said they didn’t have the