The verification required by IRC sec. 6330(c)(1) does not require an analysis of the thought process of the approving immediate supervisor under IRC sec. 6751(b)(1) but rather verification that the supervisor approved in writing the initial determination of the penalty

The verification required by IRC sec. 6330(c)(1) does not require an analysis of the thought process of the approving immediate supervisor under IRC sec. 6751(b)(1) but rather verification that the supervisor approved in writing the initial determination of the penalty
LINK TO ITEM
Code Sec. 6751(b)
Blackburn v. CIR, 150 T.C. No. 9
(USTC)
2018-04-05

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