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BELAND v. COMMISSIONER

Docket No. 30241-15.

156 T.C. 80 (2021)

156 T.C. No. 5

BRIAN D. BELAND AND DENAE A. BELAND, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 1, 2021.

Attorney(s) appearing for the Case

Matthew D. Carlson , for petitioners.

Sharyn M. Ortega , for respondent.

OPINION

This case is before the Court on petitioners' motion for partial summary judgment (motion). Petitioners contend that the Internal Revenue Service (IRS or respondent) failed to secure timely written supervisory approval under section 6751(b)(1) of a section 6663(a) fraud penalty (fraud penalty) for petitioners' 2011...

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