Attorney-at-Law

SIGN ON THE DOTTED LINE – REDUX

In Uncategorized on 12/19/2022 at 16:15

Ex-Ch J L. Paige (“Iron Fist”) Marvel says that’s all a Boss Hoss immediate supervisor needs to do. It doesn’t matter the document whereon the signature appears: here, it’s a thirty-day letter, Letter 950, and even though the chop numbers were wrong, and a CPAF issued three (count ’em, three) months later corrected the errors and added a new penalty, it’s enough to show compliance with Section 6751(b).

Rudy Kipling got it right. Once the Boss Hoss signs, “The door is shut/We may not look behind.”

 There’s “somber reasoning and copious citation of precedent” in support thereof, in Luis A. Castro and Judi A. Chavez-Castro, T. C. Memo.  2022-120, filed 12/19/22, but most of the cases are the usual suspects.

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