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GRAJALES v. COMMISSIONER

Docket No. 21119-17.

156 T.C. 55 (2021)

156 T.C. No. 3

KIRGIZIA I. GRAJALES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 25, 2021.

Attorney(s) appearing for the Case

Frank Agostino, Phillip J. Colasanto, and Andrew D. Lendrum, for petitioner.

Jane J. Kim, Mimi M. Wong, and Francesca Chou, for respondent.

OPINION

By notice of deficiency, respondent determined a $3,030 deficiency in petitioner's 2015 Federal income tax. The parties submitted this case for decision without trial pursuant to Rule 122.1 The sole issue is whether the written supervisory approval requirement of section 6751(b)(1)...

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