In Uncategorized on 03/27/2018 at 19:26

I Draw the Line at Peanut Butter and Mayonnaise

Here I am at Tango Charley Juliet, the United States Tax Court Judicial Conference, the first to be held in a time zone other than Eastern (as we were reminded by Ch J L Paige (“Iron Fist”) Marvel in her opening remarks).

And I’m soaking up learning from the sages and savants, both on and off the Bench, at a rate so furious my fingers can’t type quickly enough.

Moreover, even over a hasty lunch, the conversations of experts filled the air. The journalistic front-bench included Tax Notes’ gifted analyst Nathan Richman, and at the back The Jersey Boys held court, with promises of great blogfodder to come.

So here am Little I, a mere “general practitioner with very limited experience and mediocre qualifications,” as a much finer writer than I put it, throwing down the gauntlet to a much more distinguished member of the Bar from a high-class NYC semi-white shoe.

Contrary to my usual practice, I’ll name the gentleman: Bryan C. Skarlatos, Esq.

Mr. Skarlatos spoke of the novel jurisdiction of Tax Court under Section 7623, critically examining the limited “abuse of discretion” review and suggesting something broader. It may be his analysis will draw legislative or judicial attention, but I still make “abuse of discretion 8 to 5″, as I said in my blogpost “A Hotly-Burning Quesiton What Has Swept The Continent – Redivivus,” 7/28/17.

But my real quarrel with the distinguished counselor is over a much humbler subject. He denounced Tax Court whistleblower jurisdiction as an improper mixture, like peanut butter and mayonnaise.

I love peanut butter and mayonnaise!


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