That’s apparently IRSspeak for Boss Hossery. Or so we learn from a footnote in Marievi Garalde Palter, Docket No. 9321-25L, filed 5/18/26.
This is another unpetitioned SND case, so underlying liability is off the table at Appeals, and RCP is over the uncontestable liability, so IRS gets a walkover. But the SO checked with AUR (income from credit card payments are unreported).
“When the IRS Independent Office of Appeals (Appeals Office) Settlement Officer (SO) assigned to petitioners’ request for a Collection Due Process (CDP) hearing reviewed the case, she contacted the Automated Underreporter (AUR) coordinator for verification of the section 6662(a) substantial understatement penalty asserted in the Notice of Deficiency. …the AUR coordinator informed the SO that the substantial understatement penalty assessed under section 6662(a) for taxable year 2021 should be abated because no managerial [sic] was present on petitioners’ account. Accordingly, the SO submitted an abatement to the appropriate IRS operating division for processing… and verified that the abatement was input.” Order, at p. 4, footnote 3.
Footnote to a footnote: AUR? Isn’t that electronical, hence no “managerial” necessary per Section 6751(b)(2)(B)? But cf. the colloquy that followed my blogpost “A Couple Quirks,” 4/30/26.
Taishoff Law 
The penalty was $10,771 on a $27,244 assessment, which works out to just under 40%. There is a 40% penalty in Section 6662, but I’m not sure it applies to unreported income as described here. In any case, the computer isn’t programmed to “calculate” whether it’s a 40% case (or maybe 40% on most of it but only 20% on a little bit of it).
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Mr. Kamman, the 40% enhanced penalty in Section 6662(h) applies to “gross valuation misstatements,” clearly not an issue here.
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