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LAIDLAW'S HARLEY DAVIDSON SALES, INC. v. CIR

No. 20-73420.

29 F.4th 1066 (2022)

LAIDLAW'S HARLEY DAVIDSON SALES, INC., Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed March 25, 2022.

Attorney(s) appearing for the Case

Jacob Earl Christensen (argued), Francesca Ugolini , and Kathleen E. Lyon , Attorneys, Tax Division; David A. Hubbert , Acting Assistant Attorney General; United States Department of Justice, Washington, D.C.; for Respondent-Appellant.

William J. Wise , (argued), Chicago, Illinois, for Petitioner-Appellee.

Dissent by Judge Berzon.

OPINION

Section 6751(b)(1) of the Internal Revenue Code ("I.R.C.") (26 U.S.C.), states that "[n]o penalty ... shall be assessed unless the initial determination of such assessment is personally approved (in writing)" by a supervisor. At issue in this case is exactly when the supervisor must provide the approval...

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