I requested from Transcripts & Copies a copy of the Response to Order that within seven days petr. submit copies of Badaracco, more particularly bounded and described in my blogpost “AI AI, AI AI,” 6/12/26. Said Response was e-filed 6/18/26, but is not available otherwise than on request and payment of the fee.

I quote from the Preliminary statement (footnote omitted).

“I accept responsibility for the citation errors the Order identifies. The errors are mine, not the client’s, and they did not reach Petitioner’s post-trial briefing. Petitioner attaches the opinions the Order names (Exhibits A and B), withdraws the misquotations and misattributions the Order identifies, and submits this Response in compliance with the Order. The withdrawn material appeared in Petitioner’s papers opposing the Commissioner’s motions for partial summary judgment. Petitioner confines this Response to what the Order directs and does not reopen that briefing. Because the withdrawal removes material from Petitioner’s own papers, and the Court has, by Order served June 18, 2026, granted the Commissioner’s motions for partial summary judgment, Petitioner does not address the potential prejudice to Respondent.”

The senior attorney of the Petitioner’s legal team accepts personal responsibility at p 5 of the Response.

I will not comment.

With climate science mapping the retreat of glaciers, perhaps the old simile for slow progression should be retired. So I’ll propose “geological” for “glacial” to describe the pace of Possum Rock, LLC, Carrol Beavers, Tax Matters Partner, Docket No. 22637-22, filed 7/6/27.

This is a SCE from 2016 (pre-BBA), FPAA issued and petitioned in July, 2022. So we’re now four (count ’em, four) years into the process. A quick docket search reveals that two (count ’em, two) stips of fact and one of settled issues have so far been filed. So discovery should be about finished, right? After all, this Order says the case was set for trial in May, 2026 in Atlanta (except an Order dated 6/12/26 says May, 2027).

Not so fast, says Judge Morrison.

He lists fourteen (count ’em, fourteen) items, either facts or documents, unstiped and unprovided, which shall form a stipulation of (you should pardon the expression) basic facts. Like contracts of sale, deeds, reports, and what thereof was attached to the 1065 for year at issue. Of course, you might call the documents Proposed Trial Exhibits, but whatever the nomenclature, with a $19.8 million charitable deduction on the line and interest presumably running, y’all might want to put the pedal to the cliché.

From the United States Tax Court website, July 3, 2026:

Opinions are generally filed at 3:00 PM. If you are receiving this message after 3:00 PM, there are no opinions today.

No orders have been issued today.