IRS is on the receiving end of this injunction from Judge Haines, in Steven T. Waltner & Sarah V. Waltner, Docket No. 12722-13L, filed 11/9/15. Steve & Sarah are old rounders, and I’ve blogged their various delictions, as more particularly bounded and described by Judge Buch, Judge Marvel and Judge Haines before now.

Today’s episode arises out of the facts and circumstances set forth in my blogpost “A Tale of Three Lawyers,” 7/3/14. Judge Haines was looking for grounds, if any, to impose a mulct on Steve’s & Sarah’s lawyer (whom I’ll call Donny). Judge Haines wanted IRS to tell him what Donny’s time-wasting tactics cost the Federal fisc, but to leave out “…costs incurred before petitioners’ counsel entered an appearance in this case or costs attributable to the issues of (1) whether the statute of limitations on assessment and collection applies in this case; (2) whether petitioners had unreported income from the sale of assets in Mr. Waltner’s Citigroup account; (3) whether petitioners are liable for an accuracy-related penalty under sec. 6662(a); and (4) whether petitioners are liable for an addition to tax under sec. 6651(a)(1).”

Well, IRS’ attorneys (who didn’t do so well before, as described in my abovecited blogpost) fail the test.

“Respondent [IRS] has provided generalized descriptions of the time spent by his attorneys, and it appears that such time may include time spent during the ordinary course of litigation. Respondent must provide a more detailed description of his attorneys’ time so that excess costs can be distinguished from costs ordinarily incurred during the course of litigation. If respondent cannot provide such information, we will be forced to make a reasoned determination as to the difference in the amount of time spent in this case and the amount of time ordinarily spent in litigating a section 6330 Collection Due Process case.” Order, at p. 1.

Subtext- Don’t expect as good a number from the Judge as you can provide for yourselves.

Or as they say when the UK pubs are closing, “Time, gentlemen, please.”