When I asked recently for feedback from readers, frequent commenter Bob Kamman, Esq., facetiously suggested “(M)ore opera reviews. Every Tax Court case is the same, but every Met production is different.” While not quite so obliging as Judge David Gustafson, I am willing to try.

It’s been years since I last saw Eugene Onegin at the Met, but happy memories persist, so I looked forward to last night’s (April 23) performance. There was plenty to like, but a perfect performance is not yet.

In an almost all-Slavic cast, Frenchman Stanislas de Barbeyrac was a stand-out Lenski, great power and presence, and made you believe he was a poet. He dominated the second act, which is quite a feat, as Maria Barakova’s Olga was one to remember. Barakova, who must stand close to two (count ’em, two) meters tall with voice to match (classic Russian iron-throat mezzo), looked ready to beat up both tenor and bass-baritone singlehanded, despite being twice floored during a hyperathletic struggle with her jealous lover.

Lithuania contributed Asmik Grigorian, for which many thanks. An incandescent Tatiana in the badly-staged letter scene, she turned it up in the third act. Likerwise, I do not grasp why Deborah Warner has Iurii Samoilov stagger about the stage in the third act as if he were playing the Flying Dutchman in a full gale.

Speaking of Samoilov, he has a serviceable voice wanting a certain darkening quality for Onegin. He seemed entirely too genial for the role, which needs a Byronesque brooder. For me, Sherrill Milnes had the darkness and brood the role demands, plus of course the voice. It may be the staging; an ultra-physical Onegin isn’t true to the text.

Speaking of staging, using a single set for first and second acts may be easy on the stagehands and the budget, but playing the letter scene other than in Tatiana’s bedroom (as was done in the 1977 production I remember) is like watching from the bleachers a skilled gemcutter at work on the pitcher’s mound in Yankee Stadium. The smallness of the bedroom enlarges the passion and tension of the scene. Tatiana must be trapped in the moment emotionally and physically. Grigorian had to do it all with her voice and body; she could have done with help from the stage setting.

I know the current fashion in operatic staging is to have the singers doing basic infantry training PT while belting away; I find it impressive, really I do, but it might be well to rein it in a wee bit. Tenors and bassos flinging sopranos around takes some of the magic away.

Tony Stevenson was a magical Monsieur Triquet, and the minor roles are well-served. Good to see Richard Bernstein again, even briefly as Zaretski.

Cannot finish with a loud “bravo” to conductor Timur Zangiev. He reached the ultimate degree of what G. B. Shaw described as the goal of an operatic conductor. He got the Met orchestra to play so as to cause concussion of the brain.

That’s how Judge Cathy (“NCY = No Cognomen Yet”) Fung sees Section 7517, so she denies summary J to Estate of Kurt A. Amplatz, Deceased, Security Bank & Trust Company, Personal Representative, T. C. Memo. 2025-35, filed 4/23/26.

True, IRS never responded at either of the two (count ’em, two) opportunities it had when SecBank asked them for the Section 7517 bukh on how they got their valuation numbers, wherewith to whack the Estate with the Section 6662(b)(5) and (g) estate tax 40% substantial undervaluation chop. IRS says the Form 886 or their expert’s report did the trick, even though IRS never said so until they moved for summary J.

“Even assuming arguendo that respondent did not comply with section 7517, the remaining question is what remedy, if any, is available to the Estate. As a consequence of respondent’s noncompliance, the Estate asks us to preclude respondent from asserting the value of Mr. Amplatz’s estate determined in the Notice of Deficiency—$15,145,000. Precluding respondent from asserting his determined value would leave us with the Estate’s asserted value of zero, rendering the Notice of Deficiency essentially hollow. We decline to grant that relief. The Estate cites no authority to support its requested relief, and we are not aware of any such authority. We presume the ‘legislature says in a statute what it means and means in a statute what it says there.’ By its plain text, section 7517 does not suggest any consequence for noncompliance, let alone the harsh result the Estate seeks. 

“We have previously declined to impose severe consequences for noncompliance where the statute itself supplies no enforcement mechanism.” T. C. Memo. 2026-35, at pp.10-11. (Citations omitted).

If the Estate feels it’s been prejudiced by the nonresponse to its Section 7517 ask, “…the Estate may obtain any other necessary information through discovery. With respect to an expert appraisal under section 7517(b)(3), the statute does not contemplate that the Commissioner employ an expert appraisal in all cases. Section 7517(b)(3) refers to ‘a copy of any expert appraisal made.'” T. C. Memo. 2026-35, at p. 12. (Emphasis by the Court). Here, the expert’s report hadn’t yet been prepared when the Estate made its Section 7517 request.

It is for Congress to provide a remedy.

Of course, by this late date, IRS gets the Boss Hossery right.

Cathryn A. Simmons, T.C. Memo. 2026-34. filed 4/22/26, ran a shop thus entitled with her sister, which sold “handmade and small-batch specialty goods,” T. C. Memo. 2026-34, at p. 2. Cathryn and sister funded operations with multiple credit cards and family loans, all in their individual names.

Ch J Patrick J (“Scholar Pat”) Urda holds the interest the sisters paid on these were personal interest, as their documentation that these were obligations of Stuff, their box-checked LLC. Ch J Scholar Pat also notes that neither the Cathryn’s trusty attorney nor IRS’s counsel raised TEFRA or BBA, but the partnership-level adjustments appear to be correct, T. C. Memo 2026-034, at p. 5, footnote 4.

Want of documentation writes off much of what IRS doesn’t concede, but Stuff’s charity party deductions survive.

“The Commissioner here concedes that Stuff spent $4,407 on advertising and promotion expenses and $20,668 on its charity parties. He asserts, however, that Ms. Simmons did not carry her burden to show\ that the party expenditures served a legitimate business purpose. We disagree. As Ms. Simmons’s sister testified, Stuff used its associations with charities to promote the purchase of its merchandise. For over a month near the end of the year, Stuff hosted parties for various charities, which typically received 15% of the sales from the day or evening of the party. By tying charitable contributions to sales on a particular day, Stuff leveraged the milk of human kindness to encourage customers to visit its store and purchase its merchandise. Stuff saw the expenses associated with its charitable parties as a means to drive sales, and we conclude that they were legitimate business expenses.” T. C. Memo. 2026-34, at p. 12.

Caution is advised, however, before you cite this case in your next charitable donation memo of law.

“Relying on Treasury Regulation § 1.162-15(a), the Commissioner argues that Stuff’s charity party expenditures were not legitimate expenses because they were not made with a reasonable expectation of financial return commensurate with the amount of payment. We note that the version of the regulation on which the Commissioner relies was not issued until 2020 and has no applicability to Stuff’s 2017 tax year. See Treas. Reg. § 1.162-15(a)(4).” T. C. Memo. 2026-34, at p.12, footnote 10.

Cathryn’s trusty attorney did well with a poor set of facts, earning a Taishoff “Good Job, third class.”