Is a formal written communication from the IRS informing a taxpayer that penalties have been determined to apply and that solicits payment of those penalties an 'initial determination' that requires written managerial approval under Section 6751(b)?

Internal Revenue Code Section 6751(b)(1) provides that “[n]o penalty under this title shall be assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the individual making such determ ination or such higher level official as the Secretary may designate.” The question presented: Is a formal written communication from the IRS informing a taxpayer that penalties have been determined to apply and that solicits payment of those penalties an “initial determination” that requires written managerial approval under Section 6751(b)?