No, not what you need for your next memo of law.

I’ll let Judge Mark V. Holmes mansplain. “…petitioners filed a request for an answer to the question of their Virgin Island residency with the so-called ‘competent authority’ – an office within the IRS whose agents can meet with their counterparts in the VI BIR to try to settle this issue.” Order, at p. 1.

So the competent authority is a person, not a hornbook or a string-cite of cases. Sort of the maven di tutti mavonnim, when it comes to offshore tax conundra.

And who else should be worried about their Virginity (in the Section 932 sense, of course), but Renee Vento and Gail Vento, with a string of Docket numbers, but we’ll use 23527-08, filed 6/15/15, for now.

In these cases, competent authority is thinking about it, so Gail and Renee can stay on report-status track for now.

If you’re interested, I’ve blogged the Vento saga beginning with “The Non-Virgin Islanders”, 3/13/11, to “Catching Up,” 9/30/13.