Among his many talents and accomplishments, Judge David Gustafson would have been a great kindergarten teacher, as he exhibits in Carl Lawrence Collins III, Docket No. 2643-17, filed 4/13/26. As the Genius Baristas have published this order in a PDF that does not permit cut-and-paste, I cannot here include Judge David Gustafson’s exact words.

In substance, however, the trial minutes do show petitioner’s evidentiary documents with their “Doc.” numbers, thus making easy the task of the parties in citing to same and Judge Gustafson’s task of referring to them in his opinion.

IRS’ documents are not so listed in the minutes; for whatever reason I’ll not speculate. 

So Judge Gustafson has prepared a two (count ’em, two) page concordance, listing exhibit number, document(s), PDF pages (hopefully in a usable format), PDF pages, and internal numbers for each. This he attaches to his order.

I wouldn’t be surprised if, asked politely, he writes the party’s brief for them.

Abdelhafid Rahmani, Docket No. 4624-24, filed 4/10/26 entered this country in 1995; since 1996, he has been incarcerated, Order, at p. 1. He claims that since he got the $1400 stimulus credit for tax year 2021, IRS conceded that he entitled to same for tax year 2020, so the deficiency for that year is invalid.

Wrong, says Judge Ronald L. (“Ingenuity”) Buch. IRS’ failure to challenge a position isn’t a concession.

Likewise, Ab’s challenge to IRS and SSA computer transcripts showing he had no valid TIN for work in The Land of the Free cannot surmount the FRE 803(6)(A) and 902(11) “submitted by someone with knowledge” barrier.  Order, at p. 4.

Ab’s year-at-issue return failed to include the valid identification number mandated by Sections 6428(g)(3)(A) and 6428A(g)(4)(A), which define “valid identification number” as a “social security number (as such term is defined in section 24(h)(7)).” Ab has a number, but it’s not valid for US work. Ab does claim he worked for McDonald’s in 1995, but “(T)his bare allegation alone is not sufficient to show there is a genuine dispute as to a material fact. Rule 121(d).” Order, at p. 4.

Summary J for IRS sustaining deficiency.

I must say that in whatever slammer Ab has passed the last thirty (count ’em, thirty) years, there is access to a good law library, or perhaps adept jailhouse lawyers. And whatever Ab’s delictions that landed him there, he has diligently applied himself and chosen good advisors.

I’ve lost count of how many times over the last 13 (count ’em, 13) years I’ve praised that Obliging Jurist Judge David Gustafson. From trying cases in the slammer to writing and rewriting papers, and even (I’ve hypothesized) feeding the parking meter at the courthouse and bringing coffee and Krispy Cremes to the trial, I’ve chronicled no more obliging judge than he.

And today Judge David Gustafson again obliges. Carl Lawrence Collins, III, Docket No. 2643-17, filed 4/9/26, must be nearing the end of his nine (count ’em, nine) year trek through Tax Court, as he and IRS try to sort out their several concessions made at trial to avoid wasting time on briefing conceded issues.

Unhappily, as with a certain ceasefire agreement, what the parties agreed isn’t exactly clear. “Our order of March 20, 2026 (Doc. 164) directed the parties to report on such concessions by March 30, 2026. A status report filed that day (Doc. 166) advised that ‘the parties do not anticipate further stipulations or concessions.’ We expected otherwise. The parties’ briefs begin to be due on May 15, 2026. (See Doc. 167.) To facilitate the focused preparation of those briefs, we will order the parties to make the record clear.” Order, at p. 1.

Whereupon Judge David Gustafson expends three-and-one-half (count ’em, three-and-one-half) pages of words and figures setting forth exactly what he extracts the parties to have orally conceded from the trial record. His order directs them to show cause why these, which he schedules, should not be put into the record. Order, at pp. 5-6.

How’s that for obliging?