No, I cannot retell the celebrated limerick concerning said Turkish cadet, at least, not in a blog meant for a family-valued audience. But the second line thereof, relating to the “darnedest one yet”, definitely comes to mind when reading the opinion of The Judge With a Heart, STJ Armen, in a designated hitter, Michael Coe Buchanan, Docket No. 14777-13 L, filed 3/14/14, another Friday, so no opinions out of 400 Second Street, NW.

Mike never disputed that he never filed for the year at issue, and that the SFR and SNOD were sent to his last known address, which is his current address. So he never disputed liability. But he did dispute the NIL (Final Notice of Intent to Levy) timely.

Mike asked for an installment agreement in his 12153, but sent in no 433-A nor was he currently compliant.

But Mike has an entry in the Taishoff no-prize excuses handicap that might just sweep the boards.

STJ Armen: “In addition, in a letter attached to the Form 12153 petitioner asserted that he had worked as a news reporter/anchor in Washington, D.C., for 40 years; that he had uncovered and developed a report regarding the planned scope of the 9/11 terrorist attacks; that he had been informed that publishing the story would endanger national security; that he had agreed to withhold the report; that in return for his forbearance an official in the Bush administration had granted him ‘tax immunity’; and that all of this could be confirmed by contacting Director Robert Mueller of the Federal Bureau of Investigation.” Order, at p. 2.

Mike gets a NOD denying his claims. He petitions timely.

STJ Armen again: “In his request for a hearing and in the petition, petitioner challenges the underlying Federal income tax liability on the ground that he was granted ‘tax-exempt’ status. Petitioner’s argument fails for any number of reasons, including: (1) exclusions from gross income must be narrowly construed, Commissioner v. Schleier, 515 U.S. 323, 328 (1995) (quoting United States v. Burke, 504 U.S. 229, 248 (1992)); (2) tax-exempt status is provided in section 501 and only specified organizations, and not individuals, may be tax exempt under section 501, see generally secs. 501-521; (3) no person in the White House, or in the Government in general, may confer tax-exempt status independent of the standards specified in the Internal Revenue Code, see sec. 501, allowing the Secretary to prescribe regulations and guidance necessary to carry out the provisions of the section, see also sec. 1.501(a)-1 et seq., Income Tax Regs.; and (4) and there is no provision in the Code or otherwise that supports petitioner’s theory. In short, petitioner has raised no justiciable challenge to the existence or amount of his outstanding liability. More fundamentally, petitioner is barred from challenging the existence or amount of his outstanding liability in the instant collection review action because he did not engage with SO … during the administrative hearing by failing to present any evidence to support his allegations. See Giamelli v. Commissioner, 129 T.C. 107, 115 (2007); sec. 301.6330-1(f)(2) Q&A-F3, Proced. & Admin. Regs.” Order, at p. 3-4. (Name omitted.)

Once again, “somber reasoning and copious citation of precedents” (see Crain v. Com’r, 737 F.2d 1417 (5th Cir., 1984) from Tax Court, proving once more that it’s so much better (and more fun) to blog than to opine.

Mike, great excuse. You’re in the lead in my no-prize handicap.