On September 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Patel v. Commissioner (T.C. Memo. 2020-133). The primary issue before the court in Patel v. Commissioner was whether the IRS secured timely prior written supervisory approval for the penalties at issue as required by IRC § 6751(b)(1). The (Purported) Background in Patel v. Commissioner I enter this case with a fair bit of skepticism, due in toto to Judge Jones’