In the Age of Corona, statistics stand at center-stage, in the spotlight. We are barraged with data; peers are reviewing peers’ numbers, talking heads are speaking of little else. I myself understand little of this; whatever aptitude there was passed to one of my nearest and dearest, who spent every summer for years grading the Advanced Placement statistics examination in Kansas City.

So when my colleague Peter Reilly CPA inquired yesterday “What is more common? Cases settled or abandoned?” I could only reply “Mr Reilly, I haven’t got statistics, but I think dismissal for want of jurisdiction (late filing, no SNOD or NOD) leads, followed by want of prosecution (people filing petitions to buy time, no intention or ability to litigate). Only then comes settlement, and after that trial.”

Now I’m sure my learned readers will quote Sir Arthur Conan Doyle’s reply to the UK equivalent of the IRS, when they sent him back his pre-Sherlock income tax return that showed a heavy loss marked “most unsatisfactory.” Doyle sent the return back to them marked “I entirely agree.”

My reply to Mr Reilly (though he is too polite to say so) is most unsatisfactory; and I entirely agree.

But I have no hard figures. And I have not canvassed the trade press nor the blogosphere to see if anyone has any. As Tax Court is in lockdown and its website lists no statistician or press officer, I cannot turn to The Glasshouse for such.

I would really be grateful to anyone who can answer Mr Reilly satisfactorily.

But today we have a T. C. Memo. (Christopher Lambert, 2020 T. C. Memo. 52, filed 5/6/20, Nega, J.) and a designated hitter (Linnea Hall McManus & John McManus, Docket No. 9946-19L, filed 5/6/20, Carluzzo, STJ), to show whether there is any basis at all for any of my conclusions above set forth. I leave it to the reader to decide, after reading the opinions.