For readers unfamiliar with Kipling or G. M. Fraser, “bukh” is an Anglicized version of a Hindi word meaning to talk. In the Anglo-Indian, it takes on a further meaning of to expatiate, to provide Sir W. S. Gilbert’s “corroborative detail, intended to give artistic verisimilitude to an otherwise bald and unconvincing narrative.”

Two of today’s cases show the necessity of the foregoing.

Liangguo Chi, Docket No. 17532-24L, filed 6/24/26, seeks “the following collection alternatives: an installment agreement, an offer-in-compromise, and a lien withdrawal.” Order, at p. 1. And Liangguo also says he has $4.5 million in equity in his assets, but the Federal tax lien makes it impossible for him to borrow to satisfy the $2.5 million in tax debt he owes.

Except.

Liangguo never provides documentation for any thereof despite being given ten (count ’em, ten) months to do so. Judge Travis A. (“Tag”) Greaves gives IRS summary J sustaining the lien.

Frederick Whigham, T. C. Memo. 2026-55, filed 6/24/26, tells a tale of illness and bereavement but fails to disclose where he puts his rental income and won’t realize on his equity, Judge Rose E. (“Cracklin'”) Jenkins finds Fred’s parsimony with facts and figures is enough to deny him relief from the levy he petitioned. 

The memory comes flooding back: “Dis-miss! Fall out!” The thud of hundreds of hard rubber boot soles hitting rough asphalt; perhaps a shout. The sun setting on red South Carolinas clay and scrub pine woods and faded cream-colored World War II barracks.

I am sure STJ Jennifer E. (“Publius”) Siegel is haunted by no such recollections. I am likewise sure she neither gave nor heard the aforementioned order nor the consequences thereof. But perhaps some archetypical collective memory has stirred the following in Eric Gile & Melinda Gile, Docket No. 7142-25S, filed 6/24/26 (Happy Palindrome Week!).

“ORDERED that so much of respondent’s motion that seeks to dismiss petitioner Eric Gile for lack of prosecution is granted, and he is so dismissed.” Order, at p. 1.

Don’t Tax Court petitions get dismissed, and not people? Can Tax Court give Eric get the Psalm 109:13 treatment? Might I most respectfully suggest the Order be rewritten as follows? “ORDERED that so much of respondent’s motion that seeks to dismiss the petition herein as to petitioner Eric Gile for lack of prosecution is granted, and all references in said petition to Eric Gile are stricken.”

Two petitioners who’ve been here before are back, but unlike Ol’ Blue Eyes, these fare no better the second time around.

First, Albert S.N. Hee and Wendy R. Hee, T. C. Memo. 2026-53, filed 6/23/26. It’s Al’s story, all about constructive dividends from Al’s telephone C Corp and subsidiaries that paid for his kids’ education, a couple trips to exotic locations (hi, Judge Holmes), a million-dollar house near his kids’ college, and a $1246 sport coat from Saks Fifth. Judge Christian N. (“Speedy”) Weiler is all over that sport coat. Judge, so am I.

“Mr. Hee was invited to dinner with executives from Raytheon by his longtime college friend and business colleague, TP. Shortly before dinner Mr. Hee purchased a sport coat from Saks Fifth Avenue for $1,246 which he wore to the dinner. The cost of the sport coat was deducted by [C Corp] as an office expense at the direction of Mr. Hee.” T. C. Memo. 2026-53, at p. 11. (Name omitted). Doesn’t make the Section 162 ordinary-and-necessary cut, because you could wear it in the street.

All Al’s written-off largesse to self and family get shot down, with fraud chops at no extra charge. 

Charlton C. Tooke, III, T. C. Memo. 2026-54, filed 6/23/26, last here on Constitutional grounds (see my blogpost “Scrapbook, 1/29/25,” filed 1/29/25), now finds his OIC and PPIA bounced. His and former spouse’s medical problems and his current special-needs adoptee’s don’t impair Charlton’s ability to pony up the self-assesseds he owes. Giving $400K to a drug-addicted spouse, while Judge Courtney D. (“CD”) Jones doesn’t expressly say so, might could be maybe so dissipated assets.