No, not a variant on the mashbill nor another premium limited-release. I don’t even know if Judge Christian N. (“Speedy”) Weiler is a fan of Kentucky’s fine distillments. 

But I must give a second Taishoff “Good Job, First Class, With Swords and Diamonds” to Woodford, s/a/k/a Woody, the trusty attorney for Kenneth Walker & Juli A. Walker. Docket No. 2801-24L, filed 3/24/26. Woodford gets Judge Speedy Weiler to reverse his 1/12/26 decision, for whose antecedents see my blogpost “Obamasnod,” 1/8/26. 

And Judge Speedy Weiler awards Woodford’s clients $8788.50 in Section 7430 legals and admins, as well as quashing the APTC IRS assessed without first issuing a SND.

Moreover, IRS folds.

Honest representation at reasonable rates, that’s Woodford’s style.

I note STJ Peter J. (“HB”) Panuthos’ Order permitting IRS to amend its answer out of time in Ashref Zarmuh, Docket No. 7127-22, filed 3/23/26, as a cautionary tale.

IRS moves to amend out of time (that means late) to up the deficiency and the Section 6662(a) chop. Ashref’s trusty attorney objects this gives IRS “a second bite at the apple.” Order, at p. 2.

STJ HB Panuthos tells the story.

“The increased deficiency and penalty arise from gross receipts on Form Schedule C of an unsigned Form 1040 provided to respondent by petitioner’s counsel as part of informal discovery. The Form Schedule C was not part of the Form 1040 electronically filed by petitioner.” Order, at p.1.

Amendment of pleadings is granted absent prejudice.

“Petitioner has not demonstrated that he would be prejudiced by allowing respondent to assert an increased deficiency at this time. The case is not calendared for trial and no formal discovery is reflected on the record. Additionally, respondent will bear the burden of proof on this increased deficiency, pursuant to Tax Court Rule 142, thus further ameliorating any potential prejudice.” Order, at p. 2. (Citation omitted).  

Practitioner, make sure you have your client’s documents, all of them, in-hand, before you ever draft a petition. If time is short, file a generic petition and amend later. E-filing can be hazardous as well as helpful; make sure you have reviewed all documents as-filed before you file.

Edited to add, 3/23/26: Especially beware of some of these “free file e-file” software services, which don’t permit the filing of schedules.

That tactic doesn’t work in Judge Courtney D. (“CD”) Jones’ division, although the approach of the Cup playoffs makes us old-time fans recollect the great Bobby Clarke of the Broad Street Bullies doing that thing again and again.

Gurpreet S. Padda & Pamela B. Kane, Docket No. 7260-19, filed 3/20/26, and IRS tell Judge CD Jones that really truly they only need 90 (count ’em, 90) days more to stip out both this case and Docket No.15807-22.

Judge CD Jones says that’s cool but move the puck (although she puts it more elegantly than I).

“The Court appreciates the parties’ representations and will grant the requested 90 days to file a stipulated decision. Nevertheless, the Court notes that the Petition in Docket No. 7260-19 was filed more than six years ago (see Doc. 1), and the Petition in Docket No. 15807-22 was filed more than three years ago (see Doc. 1). Given the age of the cases, the parties are advised that the Court will be inclined to restore each case to the general docket so that it can be calendared for trial, if a proposed stipulated decision is not filed in 90 days.” Order, at p. 1.

I’ve often before now suggested that either the Ch J or an administrative judge traverse the dockets and bestir dilatory litigants to “stip out or try the case now.”  Moreover, she “strongly encourages the parties to meet in person, if at all possible.” Order, at p. 1. (Emphasis by the Court).

It would be presumptuous of me to award Taishoff “Good Jobs” to Judges but I can express hearty agreement with Judge CD Jones’ approach.