On May 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Davison v. Commissioner (T.C. Memo. 2020-58). The primary issue before the court in Davison v. Commissioner was whether petitioner is liable for a penalty under IRC § 6700 (promoting abusive tax shelters, etc.) for consistently promoting a tax avoidance scheme that everyone and their mother told him (and that he objectively knew himself) to be contrary to the law. (This