§6571

We have consistently held that a manager’s signature on a NOPA or penalty approval form—without more—is sufficient to satisfy the statutory requirements. See Palmolive Bldg. Invs., 152 T.C. at 86; Estate of Glass- man v. Commissioner, T.C. Memo. 2024-51, at *6; Green Valley Invs., T.C. Memo. 2025- 15, at *35. No court has ever interpreted section 6571(b)(1) to require the supervisor to produce what petitioner calls a “narrative explanation” of his approval. In short, even if the APA’s judicial r

- 16 - We likewise find no support in section 6671 for the view that TFRPs are not "penalties." Section 6671(a), which sets forth "Rules for Application ofAsses- sable Penalties," provides that penalties under subchapter B "shall be assessed and collected in the same manner as taxes." Section 6665(a)(1) similarly provides that accuracy-related penalties, fraud penalties, and other amounts imposed under sub- chapter A "shall be assessed, collected, and paid in the same manner as taxes." Th