Not for STJ Diana L (“The Taxpayers’ Friend”) Leyden, and not an entry in the Taishoff no-prize sweepstakes, but the excuse proffered by Kit T. Klekamp, Docket No. 14517-19S, filed 4/20/21, is very close to the story I heard a couple months ago (hi, Judge Holmes) from an old friend.

Kit was an IT type, who had a job and an S Corp. His return omitted the S Corp but provided Sched C. In any case, Kit’s numbers were sketchy.

“Petitioner relied upon his girlfriend to help him keep track of his receipts and expenses on her computer. Sadly, his girlfriend passed away in March 2017 and since then he has been unable to access her computer.” Order, at p. 6.

Of course, STJ Di is sympathetic to Kit’s loss, but his numbers can’t clear the Section 274 substantiation bar.

My old friend’s neighbor (friend for many years but not a “girlfriend,” as that term is commonly used) was a financial type who ran his bank accounts and stock portfolio, and apparently did very well for him, until she died. Fortunately, he had kept his account numbers and passwords, because her computer and all records were sealed at her death. Revoking powers of attorney and access authorizations was a burdensome and grievous task.

Takeaway- Always have a succession plan for your trusted people in place.