Attorney-at-Law

FOLLOW-UPS

In Uncategorized on 03/09/2020 at 19:28

No T.C.s, Memos., or Sum Ops, or designated hitters today, but there are some appearances from old cases. So in case anybody cares, here they are.

Suzanne Jean McCrory, Docket No. 17861-18W, filed 3/9/20, folds a trio of whistleblowings, but Judge Patrick J. (“Scholar Pat”) Urda wants IRS to weigh in. Y’all will remember Suzanne Jean, the petitioner whom Judge Vasquez thought could never get a remand. But ex-Ch J Michael B (“Iron Mike”) Thornton thought she could, and gave her a full-dress T. C. See my blogpost “Anyone Can Whistle – And Get Remanded,” 4/11/19.

Next is an even older relic, Estate of Jeanette Ottovich, Deceased, Randy Ottovich, Harvey Ottovich, and Karen Rayl, Executors, Docket No. 25781-12L, filed 3/9/20. Unfortunately, today Judge Mark V Holmes has no more glorious old historical tidbits, such as the gem to be found in my blogpost “Trust Judge Holmes,” 4/20/18. Today it’s only a holding pattern until CA probate sorts out who administers what the late Jeanette owned, and substantiates the estate tax deductions.

Finally, Good Fortune Shipping, S. A., Docket No. 25327-12, filed 3/9/20. This is the follow-up to my follow-up to my blogpost “The Secret Sharer – Part Deux,” 11/1/18, as updated 2/21/20. The Good Fortunates’ attorney, having won in DC Cir, thereby tossing IRS’ blanket-toss of bearer stock in the Section 883 maritime largesse stakes, wants to bail: “…petitioner’s assets had been sold after the year in issue, that the corporate petitioner is defunct, and that his putative clients did not wish to spend any more money on the case.” Order, at p. 2.

My kind of clients; having grabbed the boodle, they scarpered.

Judge Mary Ann (“S.E.C. = She Eschews Cognomens”) Cohen tells us the rest of the story.

“Respondent filed a Motion to Dismiss for Failure to Properly Prosecute on the ground that petitioner had abandoned the case. Petitioner’s counsel declined an opportunity to respond to the motion.” Order, at p. 2. So would I have done, if my client had hied themselves off and told me they weren’t paying me.

The sole issue is whether the secret sharers were US persons, and they had the burden of proof thereon. Having not brought forth anything but hearsay declarations and presented no witnesses, Judge Cohen tosses the Good Fortunates and hits them with the $143K deficiency.

Note to IRS- Best of luck finding them. I’ll wager that, in the immortal words of the late great Charles Edward Anderson Berry, they’re “gone like the cool breeze.”

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