Well, practitioner, you’ve come to the right place, because Judge Travis A. (“Tag”) Greaves can give you one prêt à porter if you intone or inscribe the magic language indited by Amy Sanders, Esq., Senior Vice President, General Counsel, and Secretary of Avient Corporation and Subsidiaries, Docket No. 2890-25, filed 7/23/26.

And to save y’all the trouble of looking it up and typing, here it is to cut-and-paste at no extra charge.

“Ms. Sanders avers that petitioner maintains stringent protections for confidential information and has undertaken significant efforts to prevent the disclosure of competitive information, trade secrets, and proprietary information. The declaration further states that records relating to the activities of petitioner’s Board of Directors are strictly confidential and are subject to multiple layers of safeguards to prevent disclosure. Finally, the declaration explains that disclosure of petitioner’s board materials, strategic business information, merger and acquisition analyses, financial and market analyses, trade secrets, third-party agreements, and confidential human resources data would provide competitors with a competitive advantage and would cause irreparable harm to petitioner.” Order, at p. 1. 

Judge Tag Greaves, ever mindful of his Senate confirmation promise to “make every effort to balance the need to help these taxpayers understand the court’s rules and procedures with my duty to remain independent and impartial,” gives Amy and the Avients the green light.

“After careful review of the declaration submitted in support of petitioner’s motion, we conclude that petitioner has established good cause for protecting the categories of information identified in the proposed discovery protective order. Petitioner has established through competent declaration testimony that disclosure of its proprietary information could result in competitive and economic harm.” Order, at p. 2. Good job, Amy.

There follows seven (count ’em, seven) pages of a total Rule 103 blitz.

Hallemeier. It was a great thing to be a man.  There was something immense about it. R.U.R., Act Three

I got an email this morning from a former colleague, an attorney at one of the big-league tax controversy litigation firms. He announced the start of an online subscription service, to which he offered me access at no charge. This service electronically scans each day’s Tax Court grist, separating wheat from cliché, and delivering a digest thereof.

All I need do is distill same, and the day’s blogpost(s) are done, untouched by human hands, much less by human mind.

I declined. “As for subscription services, I am retired and don’t mind looking through orders and opinions. And writing my own commentary. I am sure AI will render me, and you, obsolete and redundant, but while I can, I will continue my own way. Thanks anyway.”

See supra as doubtless data centers say.

When we hear our equivalent, the reflex takes over; one hand grabbing for the steel pot, the other trying to one-hand one’s way into the flopping flak jacket, the mind trying to remember where we put that extra box of 7.62 FMJ ball. “You are the third lawyer I’ve consulted, and the other two are morons.” Get ready for a big-time firefight, and the enemy isn’t the only one shooting at you.

Judge Cary Douglas (“C-Doug”) Pugh tosses Michael V. Kervin’s and Stacie L. Kervin’s three (count ’em, three) conjoined cases (Docket Nos. 22378-22, 10249-23, and 482-24) for want of prosecution.

Judges Travis A. (“Tag”) Greaves and Benjamin A. (“Trey”) Guider III both folded when confronted by plaintive tales of illness, natural disasters, and requests for yet further continuances.

Finally, Judge C-Doug Pugh has had it. IRS asked for an OSC, and Judge C-Doug Pugh granted it, telling Mike and Stacie to show specific documents they would put in on the trial to substantiate income and deductions.

” Petitioners’ response… failed to do any of this. Rather, it stated that petitioners needed additional time to respond. And it stated that as a show of good faith and concrete progress petitioners had hired a new tax preparation firm to review and correct their 2018 and 2019 returns (if necessary) and prepare returns for 2020 through 2025. Petitioners also cited their newly hired tax preparation firm as a basis for their… Motion for Continuance… which we denied…. Hiring a tax professional may be an important step in bringing petitioners into compliance with their federal tax obligations but it does not address the issues in the pending cases—namely, what evidence they would offer at trial to support their claimed income and deductions. Their repeated nonresponses affirm the Court’s conclusion that they do not intend to provide any evidence of their income and deductions but rather seek only to delay the inevitable.” Order, at pp. 1-2.

Judges, counsel, and preparers, it’s all the same story. When you’re the third, look out.