In Uncategorized on 04/11/2019 at 17:39

No, this is not a plot suggestion for a defunct television series. This is real-life L. A. Law, featuring a real-life L. A. lawyer (whom I don’t know) with a client who has to be in the top-fuel wag, wit and wiseacre category.

And who better to decant for us this ya-can’t-make-this-stuff-up tale than STJ Lewis (“A Name to Inspire Legends”) Carluzzo?

Here’s an off-the-bencher designated hitter, Mohamed A. Hadid, Docket No. 14213-18L, filed 4/11/19.

Mo was in the hole four-for-three. That means $4 million in tax liabilities for three (count ‘em, three) tax years. Mo doesn’t dispute this. IRS wants to levy, and Appeals says “go right ahead.” Mo and his trusty L. A. attorney, whom I’ll call MG, petition.

There’s a brief joust over the administrative record, as they’re in record-rule LaLa Land. STJ Lew says “mox nix, let it all in.”

Mo wants an IA.

“As a collection alternative to the proposed levy, Petitioner requested an installment agreement and offered to pay $30,000 per month towards the underlying liabilities. In support of his request for the installment agreement, petitioner provided a financial statement showing that he had $5,000 of monthly income and more than $200,000 of monthly expenses. Petitioner’s offer was conditioned upon respondent’s agreement that a Notice of Federal Tax Lien (NFTL) would not be filed with respect to the underlying liabilities.” Transcript, at p. 5.


“At trial petitioner’s attorney acknowledged the obvious mathematical implications,  but suggested that the money would come from somewhere.” Transcript, at pp. 5-6.

I was about to suggest Shangri-La, when I recalled the death yesterday at age 103 of Col. Dick Cole, the last living Doolittle raider. President Roosevelt said the raiders came from Shangri-La.

I award MG a Taishoff “Good Try, Third Class.”

And we can stop here.




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