In 2017, court decisions gave penalty relief to certain taxpayers. Since then, the courts have clarified the scope of these decisions. Second Circuit Sets the Standard Under Code Sec. 6751(b) , certain penalties require that the immediate supervisor of the individual making the determination, or designated higher level official, personally approve “the initial determination of such assessment.” The approval must be in writing. However, Congress did not define what constitutes “the initial determination […]
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