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. 

Candidates for Ch J Patrick J. (“Scholar Pat”) Urda’s proposed hardy perennial Slaughter of the Innocents (see Proposed Rule 200(a)(3)(A)(ii), 5/26/26) will benefit from perusing Judge Mark V. (“Vittorio Emanuele”) Holmes’ apportioning of Section 6015 by awarding complete relief to Amal H. Sleiman, without a single disrespected partitive genitive.

The case is Amal H. Sleiman, Petitioner and Chad Y. Sleiman, Intervenor, Docket No. 19155-24, filed 6/22/26 (Happy Palindrome Day!).

Turns out Chad is a bad lad, dishing out physical and mental abuse to Amal and minor offspring and loading up the marital domicile with 20 (count ’em, 20) guns, which Amal discovered when the ceiling collapsed. Transcript, at p. 11.

Though you cannot quote off-the-benchers, Judge Holmes unpacks both Section 6015(b) and Rev. Proc. 2013-34. Family practitioners should delve deep into the Rev. Proc., which Taishoff says will survive a Loper Bright attack, although none is raised here. Section 6015(e)(7) again provides cover for sworn testimony on the trial, as Appeals can take none, hence newly available. 

Also, the separation agreement between Amal and Chad gets in, though why that was unavailable at Exam, which concluded in the same month as the sep agreement was signed, and hence not in the admin record, is nowhere stated, Transcript, at p. 16. However, it does appear that Chad was pro se here as he tried on cross to beat up Amal to the point that Judge Holmes had to tell him to “shut up.” Transcript, at p.12.

I note the divorce proceedings between the Sleimans was hotly contested for eight (count ’em, eight) years, with legal fees to match, Transcript at pp. 14-15. With conceded tax due of $86K, I’m surprised neither side sought counsel here.