That’s STJ Daniel A. (“Yuda”) Guy. And the people who have him disinterested are Samer Mikhail & Mariana Mikhail, Docket No. 20199-12S, filed 7/22/14, a designated hitter on a very dull day in Tax Court.

The Mikhails were told to put in their numbers on a Rule 155 beancount, after they lost a Section 7463(b) small-claimer back in April. I didn’t blog it at the time, as it was the usual Section 183 no-profit case.

IRS put in its numbers, the Mikhails didn’t, but asked Judge Guy to abate interest on the deficiency. But until numbers are computed and a decision is entered, no deficiency.

Judge Yuda: “Although the Court has the authority under section 7481(c) to redetermine the correct amount of interest due on a tax deficiency assessed pursuant to section 6215, the deficiency in this case has not been assessed, petitioners have not paid the deficiency or the interest related thereto, and their motion otherwise fails to satisfy the requirements of Rule 261.” Order, at p. 1.

So no deficiency, no jurisdiction, no abatement–and no interest.