In Re Arthur Carol Sanford, Debtor. United States of America v. Arthur Carol Sanford

FAY, Circuit Judge:

The government appeals the United States District Court’s order affirming the judgment of the bankruptcy court, which reduced Debtor’s tax. penalty liabilities by two-thirds without publishing relevant factual findings. These tax penalties were imposed pursuant to I.R.C. §§ 6651(a)(1), 6651(a)(2), and 6654(a). We hold that the penalties imposed under these sections must be waived or imposed in their entire- ■ ties, according to whether Debtor makes the factual showing statutorily required for waiver of the penalties. Therefore, we vacate the district court’s judgment and…