12/19/2022
https://taxattorneyoc.com/castro-v-commissioner-t-c-memo-2022-120-tax-court-finds-irc-sec-6751b1-penalty-approval-while-declining-to-follow-9th-circuits-laidlaw-opinion/
This is for the real tax geeks out there.
Castro v. Commissioner, T.C. Memo. 2022-120: Tax Court Finds IRC Sec. 6751(b)(1) Penalty Approval While Declining to Follow 9th Circuit's Laidlaw Opinion