Are both frustrated by Judge Buch’s magisterial wrapping-up of Tribune Media Company f.k.a. Tribune Company & Affilliates, 2021 T.C. Memo. 122, filed 10/25/21*.
Judge Buch could put me out of business as a tax blogger, with his sweeping intro, beginning with Pres. Reagan as the Gipper, later a radio announcer of the Chicago Cubs games from afar, with the President’s brilliant improvisation when the wire went down, and concluding “(C)oincidentally, it was President Reagan who signed into law the amendments to section 707 that give us the disguised sale rule found in section 707(a)(2)(B) that applies to these cases. Deficit Reduction Act of 1984, Pub. L. No.98-369, sec. 73, 98 Stat. at 591-592.” 2021 T. C. Memo. 122, at p. 6, footnote 14.
Judge Buch must have been on law review to get that many footnotes into six (count ’em, six) pages.
The case is disguised sale meets debt-financed distribution, with some remarks from the stand worth savoring. This one has all the earmarks of a classic T. C. Memo.
I’d love to give you the whole nine yards, and I will, but much later.
Tonight is the first performance this season of the Met Opera’s Die Meistersinger. And I have Balcony Box 1, seat 1. With COVID check-in, I have to leave soon. So the baseball fan must give way to the opera fan, for now.
But I’ll be back as soon as Hans Sachs knocks it out of the park.
Taishoff Law 
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