Another granite-mining Dixieland Boondockery founders in Rising Rock Partners, LLC, Robert Schill, LLC, Tax Matters Partner, T. C. Memo. 20-260-45, filed 6/2/26. It’s conjoined for trial and briefing with Edgar F. Yost, III and Deborah A. Yost; yes, that Ned Yost, the man with the two (count ’em, two) World Series rings.

But the granite-mining discounted cash flow appraisals crater, as the locals in Meriwether County, Jawjuh, don’t want granite mines in their rural hideaway. Anyway, forecasting  the results of a successful operation over 17 (count ’em, 17) years, even if the zoning objections could be met, is too speculative. The comparable sales (including Ned Yost’s own sale to the syndicators) set up a 40% gross overvaluation chop.

Judge Christian N. (“Speedy”) Weiler lists all the usual cases that have featured in the SCE saga, most of which I’ve blogged and the trade press has waded through exhaustively.

Also today we have the return of Sammy, trusty attorney, whom we saw last month in my blogpost “Five, Seven Eight, Fourteen,” 5/8/26. Now Sammy represents Mize Farm, LLC, Design, Inc., Tax Matters Partner, Docket No. 8979-23, filed 6/2/26 (Happy Palindrome Day!). Last year Judge Ronald L. (“Ingenuity”) Buch denied the Mizers their SCE write-off in an off-the-bencher, for which see my blogpost “Luke 18:14,” 12/1/25. Now Sammy wants to try Jarkesy and postponement of interest per Section 170(h).

Problem is, neither was argued until the Rule 155 beancount, which Judge Ingenuity Buch says no can do. Anyway, interest computations are not on the Rule 155 menu.

And a Petitioner

Just a handy hint to Inga and Rex, and their colleagues at IRS, about Tax Court’s response to the CCAs’ mix-and-match responses to Boechler, P. C. As the latest score is 3 (count ’em, 3) pro-Boechler (2 Cir, 3 Cir, and 6 Cir) and one against (11 Cir, following Hallmark Rsch. Collective), we can certainly expect more.

So if your petitioner, like John F. Walsh III, Docket No. 16158-25L, filed 6/1/26, is Golsenized to 10 Cir, which has thus far stood above the fray, Ch J Patrick J. (“Scholar Pat”) Urda will Judge-‘splain how to make your motion to toss.

“This Internal Revenue Code (I.R.C.) section 6330(d)(1) case, not yet set for trial, is before the Court on respondent’s Motion for Judgment on the Pleadings…. Given the relief sought in the Motion, that is dismissal, and the ground for that relief, that is that the Petition was not filed within the 30-day period of limitations prescribed by I.R.C. section 6330(d)(1), respondent’s Motion will be recharacterized and treated as a motion to dismiss for failure to state a claim upon which relief can be granted. See Rule 40, Tax Court Rules of Practice and Procedure.” Order, at p. 1.

And since Ch J Scholar Pat is nothing if not fair, he has a handy hint for John F. as well.

“If an objection is filed, petitioner should explain why he was unable to file the Petition within the above-referenced 30-day period.” Order, at p. 1. Nudge nudge, wink wink, equitable tolling.

Judge David Gustafson is obliging on steroids and a gallon Red Bull (hi, Judge Holmes). After unloading a meticulously pen-and-ink-edited off the bencher (see my blogpost “Obliging? He’ll Correct the Transcript,” 4/20/26), Judge Gustafson revisits the eScribe’s œuvre, and hands out the Matthew 23:4 treatment in Carl Lawrence Collins, Docket No. 2643-17, filed 5/29/26. 

In 25 (count ’em, 25) pages, Judge Gustafson edits IRS’ edits.

Copyediting is a lost art in this age of digitization and artificial everything, but Judge Gustafson is resolutely keeping it alive.