In Uncategorized on 06/03/2013 at 13:24

No, not Wolfgang Petersen’s 1984 fantasy “Die Unendliche Geschichte”, although this is one that Grandma and Mommy might have called “a ganze geschichte”. We now come to  Act VI (or is it VII?) of Arthur I. Appleton, Jr., Petitioner and The Government of the United States Virgin Islands, Intervenor, Docket No. 7717-10.

My fellow tax masochists and the terminally insomniac will remember 2013 T. C. 14, filed 5/22/13, wherein Judge Jacobs (that’s His Honor Judge Julian Jacobs, a/k/a Big Julie, to you, hereinafter JJJBJ) gave IRS the right-about-face and marched out Artie A. and the Virgins unspotted by any deficiency or penalty.

So JJJBJ enters a Decision and Order granting summary judgment to Artie A. and the Virgins.  See my blogpost “Farewell to the Virgins”, 5/22/13. The end, right?

No, because JJJBJ vacates his order to allow IRS, the VIBIR and a demi-brigade of lawyers to view the MOU, namely, the memoranda of understand [sic] and procedural agreements between the United States Internal Revenue Service and the U.S. Virgin Islands Bureau of Internal Revenue, with a view to appealing JJJBJ’s Decision and Order, as soon as it gets re-entered after he modifies a previously-entered protective order sealing the MOU from the common view.

Just when you thought it was finally over.

“Old lawyers never die, they just lose their appeal.”

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