I’ve often questioned why Tax Court Rules prohibit omnibus motions and multiplex EoAs. Judge Courtney D. (“CD”) Jones provides an answer in Staven A. Stover & Cynthia Stover, Docket No. 6836-24L, filed 6/11/26. Staven & Cynthia fire off a salvo under the heading of “Answer”: a Motion to Remand, a Motion to Supplement the Admin Record, a Reply to Respondent’s Answer, and a Cover Letter to Appeals.

There’s “omnibus” and then there’s “buckshot.”

Judge CD Jones is not having any of it.

“The Court has repeatedly advised petitioners that compound filings are improper; they do not conform to the Court’s Rules (see Docs. 30, 45). Petitioners must file motions directly with the Court in the manner prescribed by the Court’s Rules, which are available on the Court’s website. If petitioners wish to re-file the documents mentioned above, then petitioners must file each document separately in accordance with the Court’s Rules. Accordingly, the Court will strike petitioners’ Answer (Doc. 46).” Order, at p. 1.

Deer-in-the-headlights pro ses should check out the “Guidance for Petitioners” link on the Tax Court website, and e-mail the DAWSON Genius Baristas support crew (although Taishoff says don’t expect much).

Finally, Staven & Cynthia might try a LITC; that’s their best bet. 

Another compound that needs breaking is the term “Power of Attorney.” Judge James S (“Big Jim”) Halpern, confronted in Edward H. Fitzelle & Jane E. Croes,  Docket No. 13476-25L, filed 6/11/26 with Form 2848, designates an individual as a Power of Attorney; Form 2848 does not. Form 2848 designates a “Representative.” Form 2848 is a Power of Attorney, hence either a piece of paper or a concatenation of electrons. Forms of power of attorney other than Form 2848 designate an “Agent” or “Attorney-in-Fact.” Sometimes the last named is abbreviated as “AiF”. But all such forms are just that: forms. Why not just call a Representative a Rep, to distinguish that person from a Partnership Representative, or P-Rep?

I don’t want to spend nearly the amount of time that Judge Rose E. (“Cracklin'”) Jenkins had to spend on Mohammad Fawad Aryanpure and Malika Aryanpure, T. C. Memo. 2026-48, filed 6/10/26. Doc Mo and Doc Mal ran drive-up medical clinics of the urgent care variety. These are cash-on-the-barrelhead or active credit card operations. Doc Mo was skimming cash, depositing the day’s green one-for-you, one-for-me.

Unfortunately, trusty CPA was too trusting, disclaiming any auditory function and taking Doc Mo’s numbers at face value. Judge Cracklin’ Jenkins doesn’t buy Mo’s testimony. 

Doc Mal gets off the Section 6663 fraud chops, but Doc Mo goes down for all four (count ’em, four) years at issue. But both owe the deficiencies, as the returns were fraudulent and SOL is out for fraud.

Although Judge Christian N. (“Speedy”) Weiler acknowledged that “(P)etitioners reasonably relied on Mr. L’s advice as he had been their tax accountant for some 30 years and they had no reason to question the advice he was providing,” William P. Wells and Ruth E. Wells, T. C. Memo. 2026-49, filed 6/10/26, at p. 14, (name omitted), I have little doubt Mr. L has received, or will soon receive, The Phone Call.

See my blogpost “The Phone Call,” 4/15/14.

This time it’s a busted Dixieland boarding school rather than boondockery, but it’s the usual story. The busted school operators sell to friendly parties who do a roundy-round transfer and claim a $4.42 million deduction on what they sold to the friendlies for $200K.

The carryover charitable deductions (three years’ worth) are in the IRS Leupold, and Mr. L.’s advice how to paper this is where the red dot shows.

“He just needs to write a letter on [donee] letterhead acknowledging and thanking [box-checked LLC donor] for the generous gift of the Campus property as of December 30, 2016. It would be really good if he says he understands that the Campus has a current appraised value of $4,420,000. That is all that it needs.” T. C. Memo. 2026-49, at p. 4.

As my readers face-palm and chant “Section 170(f)(8)(B)(ii),” I note Judge Speedy Weiler covers the waterfront on integration of documents to form a CWA, and what elements a CWA must contain. And no, you cannot argue that reading between the lines would let IRS figure out that no goods or services were provided; track the statutory language.

Taishoff says, whether you have 30 years’ or 30 minutes’ experience, when a million-dollar deal is on the menu look up the statute and follow it. Or be prepared for The Phone Call.