Chutzpah often makes me shake my head in admiration. Today CSTJ Lewis (“That Magnificent Name”) Carluzzo has a truly fine example in a designated hitter (thanks, Judge), Sneeds Farm, Docket No. 24671-18L, filed 2/11/20.

Sneeds doesn’t contest they owe tax, or additions for failure to pay estimateds or late payment, or interest.

Sneeds offers an IA that ya gotta love.

“…petitioner requested an installment agreement of $5,000 per month to pay the underlying liability totaling $111,039.94…. Taking into account the financial information that petitioner provided, the settlement officer concluded that petitioner did not qualify for an installment agreement because it had sufficient equity to fully pay the underlying liability, and should either sell assets or take out a loan. Specifically, petitioner had total assets of $5,562,524 and total liabilities of $593,736, reflecting a net equity in assets of almost $5 million. Petitioner does not dispute these facts.” Order, at p. 2.

CSTJ Lew (modestly signing himself only as STJ Lew) spends another page citing caselaw, that when you have enough to pay in full, you should pay in full.