In Uncategorized on 12/05/2017 at 15:25

Even though he doesn’t indulge in head-banging to effect a settlement, I do sometimes feel a twinge of sympathy for Judge Holmes, even enough to forgo the honorifics I usually attach to his name.

He tried this case last June, but IRS says they forgot to put in the Section 6751(b) Boss Hoss sign-offs for the undervaluation and accuracy penalties. Judge Holmes is prepared to grant IRS’ motions to reopen the record to let them in.

It’s another chapter in the Graev-Chai novelette that has produced much blogfodder.

Here’s Kumar Rajagopalan & Susamma Kumar, et al., Docket No. 21394-11, filed 12/5/17. Kum & Sus wanted Judge Holmes to bang heads and settle their 40% chop (or 20% chop if the 40% didn’t fly), but he wouldn’t. See my blogpost “Old-Time Head-Banging,” 6/5/15.

So now that IRS wants to show that yes, they had the Boss Hoss sign-offs in time to assert the chops, Kum & Sus get a chance to whack the piñata.

But Judge Holmes needs Kum & Sus to cut him a wee bit slack.

“…petitioners may file a response to this motion — though a statement that their arguments in opposition are the same here as in the first motion would be welcome if true.” Order, at p. 1.

Translation: “Please don’t make me read this stuff again; have a heart, guys.”

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