Diego E. Salazar, T. C. Memo. 2026-9, filed 2/3/26, wants interest and accuracy penalties abated, but he signed an IA. Even though he says he signed “under protest and with full reservation of rights,” including “seeking a future abatement,” T. C. Memo. 2026-9, at p. 5, Judge Albert G. (“Scholar Al”) Lauber says that bars him from contesting in Tax Court.

Diego had his chance to contest at the CDP and the Supplemental, but didn’t. Moreover, he got the IA (with an unexplained $8 per month reduction) with no Form 433-A or backups. The SO invited him to submit Form 843, Claim for Refund and Request for Abatement, but he never did so, T. C. Memo. 2026-9, at p. 4. 

His complaint about the crooked preparer who got him into this mess doesn’t cross the Section 6404 threshold, T. C. Memo. 2026-9, at p. 4.

And IRS conceded equitable tolling of Diego’s late petition.