In Uncategorized on 02/08/2022 at 15:45

Today Judge James B (“Big Jim”) Halpern gives us the “corrected” version of TBL Licensing LLC f.k.a. The Timberland Company, and Subsidiaries (A Consolidated Group), 158 T. C. 1, filed 1/31/22 (although this “correction” appears 2/8/22).

It might possibly be of some little service to practitioners if I could set out of what the “correction” consists.

But Judge Big Jim doesn’t tell us.

Happily the attorneys for the parties (five for petitioner, four for respondent) can proofread the uncorrected version against the corrected. I cannot, as the Genius Baristas have obliterated the uncorrected version. And in the limited time I have before deadline, I cannot compare both versions even if available.

It would be nice if Judge Big Jim listed the corrections.

Failing that, please ignore my blogpost “Into the Woods – Part Deux,” 1/31/22


  1. We don’t have a process to identify the correction. Perhaps we should. The only change was on p. 57, changing the citation on line 10 from “sec. 1.367(d)-1T(e)(3)” to “sec. 1.367(d)-1T(e)(1)”.

    Sent from my iPad



  2. Madam/Sir, thank you. This clarification will doubtless shed great light on the matters covered by the opinion. But might it not have been easier for the correction to be made by reference to page and line, rather than republication of all 92 (count ’em, 92, and I’m sure you have) pages? Indeed, we should have a method for identifying post-publication corrections in decisions, opinions, and orders. But what effect can your comment and mine have? We are just two. We need an organization of Tax Court practitioners to assist the Court in making the entire Tax Court experience more useful and friendly to litigants and the public generally.


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