George Hani commented on Dynamo Holdings v. Commissioner, a May 2018 case of first impression in which the court found that the Internal Revenue Service (IRS) did not have the burden of production for penalties. Hani said the case was fascinating because it dealt with a new argument that the agency must have penalties approved by a manager, and if one doesn't have that approval the agency couldn't assert the penalty. Dynamo is interesting, he added, because it found "the approval process isn't applicable against penalties against a partnership. Partnerships can't avail themselves of that rule to avoid penalties."