In Uncategorized on 02/18/2016 at 15:37


Y’all will remember the battle of the letters between the Ogden Sunseteers and Thomas M. Comparini and Vicki Comparini, Docket No. 18872-13W, filed 2/18/16.

Well, if you don’t, no reason to be shamefaced about it, check out my blogpost “Arts and the Man,” 10/4/14, when Tom and Vicki starred in 143 T. C. 14, filed 10/2/14.

You’d think after a full-dress T. C., complete with a Judge Mark V. Holmes concurrence, that Tom and Vicki were quids-in, as my UK clients say.

Alas, no. Tom and Vicki were whistleblowers, and Tom turned in a party who was advertising for dirt about a third party’s tax returns. Spotting the numerous chops therefor, Tom filed a Form 211.

There followed the epistolary ping-pong eloquently lamented by Judge Holmes, q.v., as my high-priced colleagues say.

But at the end of the day, IRS brought neither a judicial nor administrative action or proceeding, and of course got no money.

So notwithstanding Tom’s and Vicki’s protestations, STJ Panuthos, detailed to hear this correspondence course, knocks out Tom and Vicki to the same old tune.

“In their response to the pending motion for summary judgment, petitioners contend that respondent’s motion is not supported by any documents. Although petitioners agree that the Tax Court cannot order the Commissioner to commence an administrative or judicial action, petitioners contend that respondent attempts to deny petitioners’ Tax Court appeal rights and that the Tax Court should sanction respondent for constitutional violations and denial of petitioners’ rights. Petitioners also disagree with our holding in Cooper v. Commissioner, 136 T.C. 597. None of petitioners’ objections, however, are relevant to whether respondent has initiated an administrative or judicial action or collected tax proceeds.” Order, at pp. 2-3.

Winning the battle of the letters isn’t enough.

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