Pay quarterly while you figure out the law. W. Virginia v. EPA (30JUN2022) set the separation of powers precedent removing all lawmaking authority (Article I) and judicial authority (Article III) from the EPA entity, including EPA environmental courts (Article II). IRS taxcourts are also an Article II entity without judicial authority, and the application of this precendent strips them of fine/penalty application via summary or declaratory judgment of IRS taxcourts.

Bottomline: IRS taxcourts got their nuts removed in 2022. And they have to go through Article III courts, conduct a trial, etc. to impose any penalties on you.