This is the first of a two-part column. The second part will be published on Tuesday.Taking a deep dive into the murky waters of Internal Revenue Service procedures, the 7th U.S. Circuit Court of Appeals considered whether the tax court correctly ruled that an administrative trap prevented Our Country Home Enterprises Inc. from challenging a $200,000 tax penalty.The question of first impression in the 7th Circuit was “whether Our Country Home Enterprises Inc. may challenge its liability for a tax penalty in a …