STJ Eunkyong (“N’Yawk”) Choi has IRS playing the Michael Corleone classical gambit to counter the silt-stirring attack on Boss Hossery from Humboldt Shelby Holding Corp., Docket No. 23763-16L, filed 8/4/22.

This long-running saga from immunologist James (“Little Jim”) Haber has been here before. Today’s disputation involves the Section 6662 chops assessed long ago and unchallenged in the deficiency proceedings which preceded the NITL and NFTL here, and the rejected OIC.

IRS wins summary J on the OIC bounce. COIC needn’t negotiate with offrerors, and letting these shelterjammers off with a grand would encourage others.

But the Boss Hossery challenge isn’t to the underlying liability. It’s a stand-alone requirement, a hapax legomenon. See my blogpost “Stir, Baby, Stir – That Silt,” 12-20/17. And verification of proper compliance is required by Section 6330(c)(1). See Order, at pp. 5-6.

Once again the Genius Baristas have posted the order in PDF, so I cannot copy-and-paste from it here.

IRS never showed proper Section 6751(b) compliance at any stage, so no summary J on the chops. Probably they’ll never be collected; looks like the tax itself is also a lost cause.