"Penalty" Means "Penalty"

Chadwick v. Commissioner (154 T.C. No. 5)

On January 21, 2020, the Tax Court issued its opinion in Chadwick v. Commissioner, 154 T.C. No. 5. The issue presented in Chadwick was whether the penalty assessable pursuant to IRC § 6672(a) (the Trust Fund Recovery Penalty or TFRP) was subject to the requirement that written supervisory approval be secured at the initial determination of such assessment pursuant to IRC § 6751(b)(1). The IRC § 6672(a) Trust Fund Recovery Penalty is…Wait for It…a Penalty

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Chadwick v. Commissioner (154 T.C. No. 5)

On January 21, 2020, the Tax Court issued its opinion in Chadwick v. Commissioner, 154 T.C. No. 5. The issue presented in Chadwick was whether the penalty assessable pursuant to IRC § 6672(a) (the Trust Fund Recovery Penalty or TFRP) was subject to the requirement that written supervisory approval be

Read More »