Short Summary: After an examination by a Revenue Agent, the IRS issued to the taxpayers a notice of determination of income tax deficiencies, a tax addition, and an accuracy-related.
The Eleventh Circuit's decision in Kroner v. Commissioner[1], is the latest opinion to address section 6751(b) and, specifically, the appropriate timing of the supervisory approval of a penalty.
Tax Litigation: The Week of December 19th, 2022, through December 23rd, 2022 Starer v. Comm’r, T.C. Memo. 2022-124 | December 20, 2022 |Wells, J. |Docket No. 615-13 Mamadou v. Comm’r,.