It’s a fact; nobody listens to me. When I went over the Bank Of New York Mellon Corporation, as Successor Interest to The Bank Of New York Company, Inc., rematch (see my blogpost “Never Borrow Money Needlessly”, 9/23/13), I laid out what I thought was a worthwhile appeal strategy for IRS.
Nevertheless, IRS caved and didn’t appeal Judge Kroupa’s Supplemental Memorandum, which granted the Mellon 15’s request that the interest on the loan Mellon took out from Barclays be an allowable deduction, even though the rest of the deal was a sham.
Well, apparently the gremlins of Tax Court repented, because “(D)ue to an inadvertent clerical error, however, the Court denied the reconsideration motion through an Order dated February 19, 2014.” Bank Of New York Mellon Corporation, as Successor Interest to The Bank Of New York Company, Inc., Docket No. 26683-09, filed 3/5/14.
So Judge Kroupa enters the above-cited order straightening this out, and the Mellon 15 get their deduction after all.
IRS didn’t listen to me. Nothing new in Tax Court today, either.
Taishoff Law 
Money always wins, Lew. Its the one legal certainty in the land.
See attachments. Im still in the game.
Bob
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Mr Jacobson, not always. But I regret to say that, though you may still be “in the game”, as you put it, you will still lose. Section 7623 is a deeply-flawed statute. It is proof (as if more proof were necessary) of Dickens’ famous words from Chapter X of his novel “Little Dorrit”: “This glorious establishment had been early in the field, when the one sublime principle involving the difficult art of governing a country, was first distinctly revealed to statesmen. It had been foremost to study that bright revelation and to carry its shining influence through the whole of the official proceedings. Whatever was required to be done, the Circumlocution Office was beforehand with all the public departments in the art of perceiving—HOW NOT TO DO IT. “
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