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CASTRO v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 2386-17.

T.C. Memo. 2022-120

LUIS A. CASTRO AND JUDI A. CHAVEZ-CASTRO, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 19, 2022.

Attorney(s) appearing for the Case

Daniel W. Layton , for petitioners.

Jeffrey L. Heinkel , Michael S. Hensley , and Richard J. Pietrofeso , for respondent.

MEMORANDUM OPINION

This case is before the Court for disposition pursuant to Rule 122.1 After stipulations, the only issue remaining for decision is whether respondent has established compliance with the written supervisory approval requirement of section 6751(b)(1) when determining accuracy...

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