Despite a law degree from a “top ten” institution and two extensions, Marilyn Letitia Randall, 2018 T. C. Memo. 123, filed 8/6/18, doesn’t file a seriatim brief in this Rule 122.

But a brief probably wouldn’t have helped, as Judge Cohen finds MLR’s legal fees in the fight over her mother’s home, and her non-institutional personal loan payments, don’t count against her monthly income nor against her RCP in this CDP.

And SOs need not negotiate IAs.

It’s a many-times-told tale, but bears repeating. If you’re going to Tax Court, go all-in. No matter where you went to school.