In Uncategorized on 11/09/2015 at 16:14

You’ll remember The Judge Who Writes Like a Human Being, a/k/a The Great Dissenter, s/a/k/a the Implacable, Irrefutable, Irrepressible, Inflexible, Indefatigable and Illustrious Foe of the Partitive Genitive, and Old China Hand, Judge Mark V. Holmes.

Well, his silt-stirring, to say nothing of his claim that Tax Court overruled Petaluma (see my blogposts “The Great Dissenter,” 12/28/11, and “Judge, He Didn’t Mean It,” 5/17/12) may come home to roost, as Ch J Michael B. (“Iron Mike”) Thornton has a surprise package for Judge Holmes.

Here’s the story, Petaluma FX Partners, LLC, Ronald Scott Vanderbeek, A Partner Other Than The Tax Matters Partner, Docket No. 24717-05, filed 11/9/15.

The Petaluma crowd are back from an unsuccessful trip to DC Circuit from which they were tossed back in August, DC Circuit deciding that a permanent reg trumped a temporary one and rendered the Petalumas quibbles insufficient to knock out the penalties which IRS laid on their Son-of-Boss sham basis-builder. Here’s the August decision from DC Circuit.

So back to Tax Court to fix the penalties.

And who gets the prize package from Ch J Iron Mike?

“…this case is assigned to Judge Mark V. Holmes for purposes of conducting any further proceedings pursuant to the just-referenced appellate mandate.” Order, at p. 1.

Stir that silt, Judge.


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