On February 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Slone v. Commissioner (T.C. Memo. 2022-6). The primary issues presented in Slone were (i) whether the IRS bore the burden of production to show timely supervisory approval of the accuracy-related penalty; (ii) whether the IRS was entitled to maintain claims against the petitioners and the trusts at issue. Editor’s Note to Slone v. Commissioner The contempt that Judge Lauber (appropriately)