On January 7, 2020, the Tax Court issued its opinion in Frost v. Commissioner (154 T.C. No. 2). The issue presented in Frost v. Commissioner was whether the IRS satisfied the burden of production under IRC § 7491(c) in offering evidence of compliance with the requirement of IRC § 6751(b)(1) that the agent initially determining accuracy-related penalties obtained timely written supervisory approval to assert IRC § 6662(a) accuracy-related penalties against the petitioner. Parsing the Semantics