In Uncategorized on 10/12/2021 at 16:09

I was eagerly awaiting the six o’clock hour, not for the Gibson but for The Great Chieftain of The Jersey Boys’ Zoomielecture on Tax Court Law and Practice, scheduled for this evening. But an early e-mail told me the lecture was postponed a week hence. No explanation. I tried to re-register, in case that was needed, but the website told me I was already signed up.

Frantic Frank’s lectures are not to be missed if you are lining up for the Slaughter of the Innocents, a/k/a the United States Tax Court admissions examination. It is a brutal ordeal, with a minuscule passing rate. Frank Agostino, Esq., is well worth your attention, however long you’ve been practicing, or for whatever examination confronts you.

Howbeit, I may have found an answer, led there by Judge Albert G (“Scholar Al”) Lauber, who, I’ll wager, could give a lecture at least equally good. It would be great to have them both on a CLE panel.

Down to business.

IRS wants to depose a couple non-party witnesses (hi, Judge Holmes) in Oconee Landing Property, LLC, Oconee Landing Investors, LLC, Tax Matters Partner, Docket No. 11814-19, filed 10/12/21*, to which the Oconees and the non-parties object, so IRS moves to compel.

Since there’s a $20 million deduction on the table (see my blogpost “Preserving the Preservation Easement,” 8/18/20), I cannot suppose the non-parties have no relationship with the appraisal at issue here. Looks like IRS has dropped the “improvements out” gambit.

So the non-parties lawyer up. And look who’s representing them!  No wonder he’s busy tonight.

*Oconee Landing 11814-19 10 12 21

  1. The change was the result of a vote to delay because the quickly approaching result October 15th tax deadlines.


  2. I was unaware that there was a vote. I really liked my explanation. Once again, it’s a case of a good story ruined by an eyewitness.


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