Another quick jotting from my notebook.

There’s just one opinion today, a Sum. Op. from STJ Panuthos, and there really isn’t much to say about it that hasn’t been said many times before. A claim is not a credit; IRS can apply payments how they wish if you don’t specify; you can’t fight about out years in a CDP or petition therefrom; and the SOL for refund claims is a real quick kick.

So you can read Robert William Porporato, 2020 T. C. Sum. Op. 24, filed 8/18/20. And perhaps you can extract more from his plight than I just did. If you do, I’d be glad to know what I missed.

Perhaps the moral is what the stick-and-string sailors say: “If you let the boat fall off to leeward, you have to make it all back at compound interest.”