Lest I be accused of disrespect for the Tax Court (or, even worse, of being “sardonic”), I omit the balance of Brendan Behan’s celebrated simile.

But when the same canned opinions repeating the same citations rain down endlessly from the glasshouse at 400 Second Street, NW, it’s nice to find something that fits the “angry sweet singer of Ireland”’s description.

“The key fact here is that the Holmeses asked for a CDP hearing to discuss the possibility of an installment agreement to satisfy their unpaid 2011 tax debt. The IRS is usually willing to talk to taxpayers who want to avoid liens or levies on their property, but understandably insists that taxpayers who want to avoid enforced collection submit honest information about their assets and income. The settlement officer handling the Holmeses’ case asked for this information, and there is no dispute that the Holmeses never supplied it.

“That means that the settlement office [sic] did not abuse her discretion when she determined to go ahead with the proposed levy against the Holmeses’s [sic] property. See, e.g., Swanton v. Commissioner, 99 T.C.M. (CCH) 1576, 1580 (2010) (no abuse of discretion when the taxpayer has not submitted financial information).”

Fred Holmes & Maria Holmes, Docket No. 14871-13L, filed 9/18/14, at p. 1.

Forget the sloppy proofreading, and guess who wrote the order. No prize for the correct answer.