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OROPEZA v. COMMISSIONER

Docket No. 15309-15.

155 T.C. 132 (2020)

155 T.C. No. 9

JESUS R. OROPEZA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 13, 2020.

Attorney(s) appearing for the Case

Tim A. Tarter, Kacie N.C. Dillon, and Jonathan A. Halmi, for petitioner.

Doreen M. Susi, John R. Gordon, Michael R. Harrel, and John W. Stevens, for respondent.

OPINION

This case is before the Court on cross-motions for partial summary judgment on the question whether timely written supervisory approval was secured, as section 6751(b)(1) requires, for three penalties determined for petitioner's 2011 tax year.1

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