Question Presented (from Petition)
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 determination 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)?
Question Presented (AI Summary)
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)?
2026-04-03
Reply of Stanley Battat, et al. submitted.
2026-04-03
Reply of petitioners Stanley Battat, et ux. filed.
2026-03-23
Brief of Commissioner of Internal Revenue in opposition submitted.
2026-03-23
Brief of respondent Commissioner of Internal Revenue in opposition filed.
2026-02-05
Motion to extend the time to file a response is granted and the time is further extended to and including March 23, 2026.
2026-02-04
Motion of Commissioner of Internal Revenue for an extension of time submitted.
2026-02-04
Motion to extend the time to file a response from February 19, 2026 to March 23, 2026, submitted to The Clerk.
2026-01-20
Motion to extend the time to file a response is granted and the time is extended to and including February 19, 2026.
2026-01-16
Motion of Commissioner of Internal Revenue for an extension of time submitted.
2026-01-16
Motion to extend the time to file a response from January 20, 2026 to February 19, 2026, submitted to The Clerk.
2025-12-15
Petition for a writ of certiorari filed. (Response due January 20, 2026)