Though I myself have never seen this, I have heard of it. I am sure Judge Rose E. (“Cracklin'”) Jenkins is unaware of the meaning of the phrase first above set forth at the head hereof (as wealthy practitioners would say).

Nevertheless, her order in Annamalai Annamalai & Parvathi Sivanadiyan, Docket No. 2398-23L, filed 3//6/26 might be so called. AA has made five (count ’em, five) trips to Tax Court, two (count ’em, two) of which have featured in this my blog thus far.

One thing about AA. Like a certain advertising rabbit, he just keeps going and going. After Judge Jenkins bounces his document production motion (which I did not blog), he replies to IRS’ winning response, unasked, asks therein for more time to respond to IRS’ summary J motion and for another copy of said motion.

“Petitioners’ unauthorized reply does not change the analysis reflected in the Court’s order. Also enclosed with the reply, contrary to the Court’s January 16, 2026, order, is a motion requesting additional time to respond to respondent’s Motion for Summary Judgment (Doc. 131), filed January 30, 2026, as well as requesting another copy of such motion. Given that the Court, in an Order (Doc. 135), issued February 6, 2026, has already extended the time to reply until April 16, 2026, no further extension is warranted, but the Court will enclose another copy of the motion with this Order. Order, at p. 1.

It’s the last sentence of the foregoing paragraph that furnishes the title hereinabove set forth and elsewhere herein referred to (as those wealthy guys would say).

After two (count ’em two) pages of Order and 27 (count ’em, 27) pages of Motion, we get to read ten (count ’em, ten) pages of AA’s account transcripts for years at issue and two (count ’em, two) billets doux, one from IRS counsel to a Bureau of Prisons employee, and one from the AO in the CDP to IRS counsel.

AA, a very wise State Court judge once told me to be very careful what I asked her for, because she might just give it to me. I did. She did. Don’t ask what happened next. It took months to straighten it out.

I don’t know if Judge Ronald L. (“Ingenuity”) Buch is, like me, a fan of the 1967 Dustin Hoffman – Anne Bancroft classic (“plastics, Benjamin, plastics”), but he sums up the newly minted graduate’s ambiguous abode in Michael D. Brown, Docket No. 14660-22L, filed 3/5/26.

This off-the-bencher is a follow-up to T. C. Memo. 2025-126, which I blogged sub. nom. “High-Flying Blogfodder – Part Deux,” 12/4/25.

OK, so where did Michael live at the material time? Credit card statements fly around like Michael’s custom-fitted Bombardier Challenger 604, Michael’s fiancé Tetyana testifies as does his Mom, but Judge Buch is none the wiser at close of play.

“This case presents a challenging set of facts. The record establishes that Mr. Brown did not have a residence of his own when he filed his petition. He no longer had his Henderson [NV] residence, and he did not live with his fiancé. Without a residence of his own, he stayed with his parents when he was not travelling.” Transcript, at p. 12.

The usual box-checks don’t help much. “We have previously looked at where people work, where their family lives, the location of their property and assets, where they attend church or social clubs, and the address they put on their income tax returns.” Transcript, at p. 12. (Citations omitted).

So here’s to Mrs. Robinson.

“We can perhaps best resolve this case by analogy. Imagine a college graduate, affianced but unemployed following graduation. Such a graduate might move in with his or her parents until a job or marital residence could be secured. Although there is no intent to remain at the parents’ residence permanently, the recent graduate has no other home. The recent graduate intends to remain with his or her parents indefinitely but not permanently. For the time being, the parents’ residence is the recent graduate’s place of legal residence.” Transcript, at pp. 12-13.

Same for Michael. No job, engaged to be married but no marital domicile, staying with parents because he has nowhere else to go.

Cue Paul and Art.

I cover Tax Court. I cover Tax Court a lot. I claim I cover Tax Court like no one else covers Tax Court. So I read a lot of orders, maybe too many, and blog a lot of orders (ditto).

But I read one order today that stopped me cold. It only said “Motion to withdraw as counsel granted.” A hand-stamped, stereotyped, run of the mill, one-and-done, like a raindrop in a thundershower.

The case is Estate of Alvin L. Glick, Deceased, Randal L. Glick, Executor, Docket No. 785-26, filed 3/4/26.

I’ve seen former clients’ names turn up in Tax Court cases, and so stated in the interest of full disclosure when I commented on the cases. But this is different.

I lost touch years ago with Al Glick (“Alvin,” indeed!), but when I saw that caption memory went into hyperdrive. I saw the gesture with the cigarette, heard the throaty rasp again putting out numbers mentally calculated accurate to two decimal places, saw the immaculate suit, tie, and shirt, and the desk crammed with paper where he could instantly grab the one he wanted. And that wonderful line, “Yeah, I went to UCLA…the University on the Corner of Lexington Avenue.” 

Randal, forsooth? Young Randal My Son? Get real. He was always Randy, and in those days twenty-plus years ago it was rarely a week gone by that we weren’t talking. The names and faces were flooding back, the office up the stairs on Third Avenue and the people I knew and worked with.

Yeah, they were tough people in a tough business. But they gave to charity. Bigly. They played hard, but they played straight. Al knew no other way.

They were good people. That’s the best eulogy I know.