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.

Last year I referred to the colonial policeman who arranged for justice against a contemptible character who mistreated a woman. See my blogpost “The Daily Grist,” 10/2/25. Now I wish he were real, and able to deal with Adam Shryock, T. C. Memo. 2026-44, filed 5/28/26.

As is often the case, a footnote tells the story. Judge Jeffrey S. (“Schwer”) Arbeit tells it.

“Petitioner also engaged in illegal activities. He solicited monetary donations from the public purportedly for breast cancer research. Several states deemed that [petitioner’s wholly-owned C Corp] and petitioner engaged in deceptive trade practices; when he continued engaging in those practices, he was held in contempt. He concealed his income-producing activities by paying personal expenses from the account of his wholly owned corporation. Finally he was convicted in federal court after pleading guilty to willfully failing to file his 2011 return. The facts in the record thus easily carry respondent’s burden of proving fraud by clear and convincing evidence.” T. C. Memo. 2026-44, at p. 9, footnote 5.

Long ago I suggested that this is less than a brilliant approach, but it would seem that Sang Hun Lee, T. C. Memo. 2026-43, filed 5/27/26, was too busy to read my blog as well as too busy to file a return for the year at issue.

Sang worked three (count ’em, three) jobs during year at issue, although IRS only nailed him for one. Sang claims the SFR he got didn’t allow him his business deductions, but STJ Jennifer E. (“Publius”) Siegel finds these undocumented. Sang’s tale of stolen records doesn’t help.

“Mr. Lee readily admits that he failed to file an income tax return for [year at issue]. He claims he had reasonable cause: Between commuting and working multiple jobs, he just did not have time. His argument is unpersuasive. We have repeatedly held that work demands—even extreme ones—do not constitute reasonable cause for purposes of section 6651(a)(1).” T. C. Memo. 2026-43, at p. 7. (Citations omitted).