IRS Penalty Approval Timely in Computing Business Tax Dispute

The IRS timely obtained supervisory approval in levying taxes and penalties on a computer company founder because that approval came before the dispute was sent to the IRS Independent Office of Appeals, the US Tax Court held Thursday.

The Tax Court cited a 2022 ruling in Laidlaw’s Harley Davidson Sales Inc v. Commissioner, which held that the supervisory approval under tax code Section 6751(b) was satisfied if the approval came before the penalty assessment, in its opinion that the IRS timely obtained approval for a tax bill on Wolfgang Frederick Kraske.

Kraske is the founder of Ovium, a computing ...