I note Judge James S. (“Big Jim”) Halpern’s grant of summary J to IRS in Arelia Margarita Taveras, Docket No. 9233-25, filed 4/14/26, for want of anything better coming out of The Glasshouse in the City At War. I’m truly sorry for the petitioner, who threw away a worthwhile career for a compulsion. She does put up a fight, but only two (count ’em, two) of her seven (count ’em, seven) objections to IRS’ summary J motion survive the Ruesch/Garcia jurisdictional limit for passport grabs. And she loses those two.

Strange that the docket number doesn’t add the “P” for Section 7345s.

Arelia is thorough, but the barrier remains. Is there an assessment of a seriously delinquent tax debt? Yes. Validity thereof is to be tested in deficiency or CDP litigation, not passport grabs. She had her chances.

It’s a shame Arelia can no longer exercise her considerable abilities in her chosen profession.

Among his many talents and accomplishments, Judge David Gustafson would have been a great kindergarten teacher, as he exhibits in Carl Lawrence Collins III, Docket No. 2643-17, filed 4/13/26. As the Genius Baristas have published this order in a PDF that does not permit cut-and-paste, I cannot here include Judge David Gustafson’s exact words.

In substance, however, the trial minutes do show petitioner’s evidentiary documents with their “Doc.” numbers, thus making easy the task of the parties in citing to same and Judge Gustafson’s task of referring to them in his opinion.

IRS’ documents are not so listed in the minutes; for whatever reason I’ll not speculate. 

So Judge Gustafson has prepared a two (count ’em, two) page concordance, listing exhibit number, document(s), PDF pages (hopefully in a usable format), PDF pages, and internal numbers for each. This he attaches to his order.

I wouldn’t be surprised if, asked politely, he writes the party’s brief for them.

Abdelhafid Rahmani, Docket No. 4624-24, filed 4/10/26 entered this country in 1995; since 1996, he has been incarcerated, Order, at p. 1. He claims that since he got the $1400 stimulus credit for tax year 2021, IRS conceded that he entitled to same for tax year 2020, so the deficiency for that year is invalid.

Wrong, says Judge Ronald L. (“Ingenuity”) Buch. IRS’ failure to challenge a position isn’t a concession.

Likewise, Ab’s challenge to IRS and SSA computer transcripts showing he had no valid TIN for work in The Land of the Free cannot surmount the FRE 803(6)(A) and 902(11) “submitted by someone with knowledge” barrier.  Order, at p. 4.

Ab’s year-at-issue return failed to include the valid identification number mandated by Sections 6428(g)(3)(A) and 6428A(g)(4)(A), which define “valid identification number” as a “social security number (as such term is defined in section 24(h)(7)).” Ab has a number, but it’s not valid for US work. Ab does claim he worked for McDonald’s in 1995, but “(T)his bare allegation alone is not sufficient to show there is a genuine dispute as to a material fact. Rule 121(d).” Order, at p. 4.

Summary J for IRS sustaining deficiency.

I must say that in whatever slammer Ab has passed the last thirty (count ’em, thirty) years, there is access to a good law library, or perhaps adept jailhouse lawyers. And whatever Ab’s delictions that landed him there, he has diligently applied himself and chosen good advisors.