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BLACKBURN v. COMMISSIONER

Docket No. 27721-14L.

150 T.C. 218 (2018)

150 T.C. No. 9

SCOTT T. BLACKBURN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 5, 2018.

Attorney(s) appearing for the Case

Jaye A. Calhoun , David P. Hamm, Jr. , Christie B. Rao , and Kernan A. Hand, Jr. , for petitioner.

Ardney J. Boland III and Susan S. Canavello , for respondent.

OPINION

In Graev v. Commissioner, 149 T.C. 485 (2017), supplementing and overruling in part 147 T.C. 460 (2016), we held that the written approval required by section 6751(b)1 must be established as part of the Commissioner...

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