That’s Jamie B. Hall, T. C. Memo. 2022-82, filed 7/28/22. Jamie’s argument why she doesn’t owe income tax on two trusts (which aren’t trusts at all; no trust instruments, no transfers of title to property) is that Social Security Administration issued a Social Security card to her.

“Petitioner argues that the Social Security Administration created the Jamie Bennett Hall trust by assigning to her a Social Security number and a Social Security card. She argues that the property originally held in the purported trust is the Social Security card and that the Social Security Administration purportedly indicated an intention to form the trust by sending her this card. Petitioner states that the beneficiary of the purported Jamie Bennett Hall trust is the U.S. Government, and therefore the trust is a U.S. Government agency trust and is not taxable. Petitioner further argued that, because respondent determined that she is liable for deficiencies and additions to tax as an individual, respondent used ‘inappropriate forms to come up with Notices of Deficiency.’” T. C. Memo. 2022-82, at p. 4.

Judge Alina I. (“AIM”) Marshall ripostes to this gibberish with a walking barrage of “somber reasoning and copious citation of precedent.”

This is old-time, worn-out protester jive. Jamie goes down for the whole boat, deficiency, add-ons, and chops.

“The issuance of petitioner’s Social Security card is not a transfer of property that creates a trust, as petitioner contends. Petitioner has not provided any legitimate trust documents forming the purported trust. The purported trust does not reflect economic reality and is not recognized for income tax purposes. Accordingly, we sustain respondent’s deficiency determinations….” T. C. Memo. 2022-81, at p. 5.

Judge AIM doesn’t mention Section 6673. Maybe she should have.