In Uncategorized on 12/22/2014 at 17:43

No, not the 1984 Boston boy band, and these certainly aren’t kids, but the latest additions to the Tax Court bench.

Please join with me to welcome Cary Douglas Pugh and Tamara W. Ashford, both bringing impressive resumes, to 400 Second Street, NW. Judge Ashford’s doesn’t show up on the Tax Court site yet, although Judge Pugh’s is there. I wonder why; but then again, President Obama’s announcement of Judge Ashford’s appointment, replete with Judge Ashford’s cursus honorum, is fully webified.

Now they can start wading through protester jive, Section 152 relativity, professional and amateur dodgers, nonfilers, late filers and rounders that we lonely bloggers confront every day, although our credentials are much less impressive.

Here’s a sample, courtesy of Judge Cohen, Hamlet C. Bennett, 2014 T. C. Memo. 256, filed 12/22/14.

And it’s just a sample, but it will give Cary and Tam a taste of their future.

“We reject any inference that petitioner’s persistence in his frivolous theories demonstrates sincerity or good faith or is otherwise a defense to the charge of fraud. Petitioner filed tax returns for decades before 1995, stopping only after he faced large tax liabilities for 1993 and 1994. He ‘discovered’ his various frivolous arguments in alleged reliance on a carpet cleaner turned tax adviser, while disregarding the cautionary advice of his certified public accountant. He adopted various means of concealing income by diverting income to nominees or to entity accounts. He rejects the judgments of the courts, including a jury verdict, a District Court judgment, and an appellate court opinion that he was criminally responsible for his conduct. A person with his education and skills could be expected to abandon unsuccessful arguments if acting in good faith. We conclude that petitioner’s failure to file for each year in issue was due to fraud.” 2014 T. C. Memo. 256, at p. 12.





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