Oxbow Bend LLC v. Commissioner T.C. Memo. 2022-23
On March 21, 2022, the Tax Court issued a Memorandum Opinion in the case of Oxbow Bend LLC v. Commissioner (T.C. Memo. 2022-23). The primary issue presented in Oxbow Bend LLC v. Commissioner was whether a telephone conference in which IRS agent stated to taxpayer’s representative what adjustments would be made and what penalties were under consideration constituted an “initial determination” of penalties that would require timely supervisory approval under IRC § 6751(b)(1). Held: Not