On December 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Pfetzer v. Commissioner (T.C. Memo. 2021-145). The primary issue presented in Pfetzer was whether the settlement officer failed to fulfill duty to verify that valid notices of deficiency were issued and mailed to taxpayer. Held: You betcha…but the IRS still managed to lose. Background to Pfetzer v. Commissioner The petitioner was not a model taxpayer. In point of fact, the