Ninth Circuit Opines on Section 6751(b) and its Application to Assessable Penalties

Tomato, Toma-toe: IRS’s Imperfect Designation of “Immediate Supervisor” Deemed Insufficient to Overturn Penalties Under Code Section 6751(b)(1)

A Taxpayer Victory on Section 6751(b) Grounds

The IRS and Fraud Penalties: Recent Case Addresses the Approval Requirement

Tax Shelters, the Reportable Transaction Penalty, and the Graev’ Supervisory Approval Requirement for IRS Penalties

The Tax Court Determines §6672 Penalties are Penalties Subject to §6751(b) Requirements

The IRS Satisfies its Burden of Production under §6751(b) With Signed Penalty Approval Form