In Uncategorized on 11/15/2016 at 15:20

Dear readers, I do not recommend trying that answer in the courtroom, or anywhere else.

But counsel for Taishan Investments, LLC, Bruce Elieff, Partner Other Than The Tax Matters Partner, Docket No. 8404-13, filed 11/15/16 does just that.

Now Judge Chiechi is not the most choleric of judges.  But counsel is pushing hard, and the result may be rather unpleasant.

Briefly to set the stage, IRS “…represents that respondent intends to send to petitioner on or before November 18, 2016, a final closing agreement. Respondent further represents in respondent’s supplement that ‘[p]etitioner’s counsel informed Respondent that she will be unable to review and/or have Petitioner Bruce Elieff sign the Closing Agreement until February 2017. Petitioner’s counsel informed Respondent that she is currently involved in significant litigation that she expects to last through January 2017.’” Order, at p. 1.

Judge Chiechi: “The Court is incredulous, and will not accept without further detailed, justifiable explanation, that the fact that petitioner’s counsel ‘is currently involved in significant litigation’ will preclude her from reviewing and/or petitioner from signing the closing agreement until February 2017.” Order, at p. 1.

If you tell a Judge that the case before him/her is not “significant” enough to merit your attention, your client may have to answer for your nonchalance. Until, of course, your client gets slammed and turns on you.

So, counsel, get on the keyboard with your “detailed, justifiable” reason why you can’t sign off on the final closing agreement until February, 2017.

And have it in Judge Chiechi’s extremely hot hands a week from today.


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