Penalties Under the Code
Initial Determination of Penalties

Sand Investment Co. v. Commissioner
157 T.C. No. 11

On November 23, 2021, the Tax Court issued its opinion in Sand Investment Co. v. Commissioner, 157 T.C. No. 11. The primary issue presented in Sand Investment Co. was whether the IRS obtained prior written supervisory approval pursuant to IRC § 6751(b)(1) insofar as whether the individual who made the initial determination received approval from its immediate supervisor. Held: Yeah…no dice, petitioner. Dueling Determinations The RA’s case and issue manager, Mr. Burris, signed the form

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Scott St. Amand April 19, 2022
Penalties Under the Code
Initial Determination of Penalties

Excelsior Aggregates v. Commissioner
T.C. Memo. 2021-125

On November 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Excelsior Aggregates v. Commissioner (T.C. Memo. 2021-125). The primary issue presented in Excelsior Aggregates was whether the IRS complied with the prior supervisory approval requirement of IRC § 6751(b)(1) with respect to the numerous penalties asserted against the petitioner (IRC § 6662A and IRC § 6662(a), (b)(1)-(3), (d), (e), and (h)). Held: Executive Summary from the Tax Court in Excelsior

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Scott St. Amand March 29, 2022
Penalties Under the Code
Dammit Felicia

Battat v. Commissioner
T.C. Memo. 2021-57

On May 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Battat v. Commissioner (T.C. Memo. 2021-57). The primary issue presented in Battat v. Commissioner was whether the IRS received prior supervisory approval of an initial determination of a penalty under IRC § 6751(b)(1). Same Issue, New Wrinkle in Battat v. Commissioner The IRC § 6751(b)(1) prior supervisory approval rule has been litigated with substantial regularity over the last year and

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Scott St. Amand May 11, 2021
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Sand Investment Co. v. Commissioner
157 T.C. No. 11

On November 23, 2021, the Tax Court issued its opinion in Sand Investment Co. v. Commissioner, 157 T.C. No. 11. The primary issue presented in Sand Investment Co. was whether the IRS obtained prior written supervisory approval pursuant to IRC § 6751(b)(1) insofar as whether the individual who made the

Read More »
Scott St. Amand April 19, 2022

Excelsior Aggregates v. Commissioner
T.C. Memo. 2021-125

On November 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Excelsior Aggregates v. Commissioner (T.C. Memo. 2021-125). The primary issue presented in Excelsior Aggregates was whether the IRS complied with the prior supervisory approval requirement of IRC § 6751(b)(1) with respect to the numerous penalties

Read More »
Scott St. Amand March 29, 2022

Battat v. Commissioner
T.C. Memo. 2021-57

On May 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Battat v. Commissioner (T.C. Memo. 2021-57). The primary issue presented in Battat v. Commissioner was whether the IRS received prior supervisory approval of an initial determination of a penalty under IRC § 6751(b)(1). Same Issue,

Read More »
Scott St. Amand May 11, 2021