Section 6751(b) Boss Hossery means approval of chops, not examination of chops. Thus Judge Albert G (“Scholar Al”) Lauber, whose paths take him far from his M. A. alma mater Clare College, Cambridge, and through endless GA boondockery, in Sparta Pink Property LLC, Sparta Pink Manager, LLC, Tax Matters Partner, T. C. Memo. 2022-88, filed 8/29/22.

This is an improvements-out perpetuity squawk, Golsenized Hewitt-ward to 11 Cir, where it’s a dead loser. Judge Scholar Al denies IRS summary J “… without prejudice to his resubmission of the arguments set forth therein should subsequent developments warrant that action.” T. C. Memo. 2022-88, at p. 5.

Translated from Judgespeak, that means when the Supremes put paid to this dodge.

Meantime, the Pinks’ trusty attorney tries the cross-examine RA and supervisor gambit to review the review.

“We have repeatedly rejected any suggestion that a penalty approval form or similar document must ‘demonstrate the depth or comprehensiveness of the supervisor’s review.’ Faced with assertions that IRS officers gave insufficient consideration to the matters before them, we have ruled such lines of inquiry ‘immaterial and wholly irrelevant to ascertaining whether respondent
complied with the written supervisory approval requirement.’” T. C. Memo. 2022-88, at p. 8. (Citations omitted).

As long as sign-off is obtained before the dread communication, Boiss Hoss is a done deal.