I need your help. No, I’m not asking for money.

The aim of this blog is to cover United States Tax Court in a different way from the trade press (e.g., Tax Notes, Accounting Today, Forbes) and the blogosphere. I’m aiming for a short  (around 500 words) daily summary of orders, opinions and decisions, written for the busy practitioner (Circular 230, Section 7525 type).

I was an EA for 10 (count ’em, 10) years and an attorney at law for 58 years. Now in retirement, I’m a part-time journalist because I can’t stop.

I’m writing to try to stay sane and to give back to the profession and calling I love. And maybe help some of you help a client, or a pro bono at a calendar call or LITC.

But I need feedback. Is this blog helping? What’s wrong? What needs changing? Too much editorializing? Not enough detail? Needs more (or less) quotation from the order or opinion? Daily format too much for your overflowing inbox?

Please comment below. I promise to read and consider all responses.

Thanks.

Lucas Calhoun, Docket No. 4554-25L, filed 4/17/26, should have been at least considered for a referral to a LITC by Appeals. When Lucas claimed he was disabled and would need help either from his father or his son, sending a couple 2848s (hi, Judge Holmes) really doesn’t answer the problem. 

Of course, the IRM contains no such instruction; IRM 8.6.1.5.3.2 (09-25-2019) places the burden on the taxpayer to request representation and to select and qualify the representative. So I’m not saying the SO did anything wrong; he followed the book, and so did STJ Diana L. (“Sidewalks of New York”) Leyden in affirming the SO sustentation of the NITL.

But when a petitioner claims “I Lucas Calhoun was in a car accident in 2018. I was a passenger in a Honda Accord that struck another vehicle head on at 50 mph. We have had a supervisor from the IRS tell us I am not collectible. Also I have a voicemail from Biran at the IRS stating that he spoke to his supervisor and we would not be held liable. To not worry. That was on 6/14/24. Please do not levy the property my dad has my son & I staying at. Please send forms for forgiveness”, Order, at p. 2, maybe so might could be that a nonlawyer nonpractitioner might not be enough.

No one shows up for Lucas, so STJ Di gives IRS summary J.

Maybe so might could be referral to a LITC could save the day. But the SO shouldn’t have to judge this without some cover from high command. Maybe a revision to the IRM? Gives no rights to taxpayers greater than they would otherwise have.

Kelby Daniel Reyes Barrios, T. C. Memo. 2026-32, filed 4/16/26, says he didn’t get the 1099-NEC from his employer until after he filed his return. Too bad, says Ch J Patrick J (“Scholar Pat”) Urda.

That doesn’t mean you don’t owe tax. Third-party information, unchallenged, is sufficient connectivity between income and taxpayer. Especially is that so when you got the money.

“The failure to receive tax information forms, however, does not excuse a taxpayer from his obligation to report income. See, e.g., Jones v. Commissioner, T.C. Memo. 2010-112, 2010 WL 2011013, at *8; Du Poux v. Commissioner, T.C. Memo. 1994-448, 1994 WL 479018, at *1 (‘[F]ailure to receive tax documents does not excuse taxpayers from the duty to report income.’).” T. C. Memo. 2026-32, at p. 4.

Summary J to IRS.