Tax Court 
Is Timely and Meaningful IRS Supervisor Approval Needed in Order to Assess Penalties?
Jesus R. Oropeza and Fabiola Anaya Oropeza, Petitioners v. Commissioner of Internal Revenue, Respondent T.C. memo, 2020-111 | Filed July 21, 2020 The Internal Revenue Code (the Code) requires the IRS to come forward with sufficient evidence that indicates the impositi... Steven R. Diamond, CPA, USTCP