In Uncategorized on 08/05/2022 at 19:14

I guess STJ Eunkyong (“N’Yawk”) Choi’s appointment on 12/6/21 was a step just behind STJ Adam B (“Sport”) Landy’s, making her the most junior member of the Tax Court Bench. So she gets what we used to call the S details.

If you must, see my blogpost “Michael Corleone at the Silt Stir,” 8/4/22.

Today, STJ N’Yawk Choi has three (count ’em, three) more CDPs with defective Boss Hossery, namely, viz., and to wit, Vance Finance and Holding Corporation, Docket No. 23761-16L, Day Stores, Inc., Docket No. 22860-16L, and Seashore Broadcasting Corporation, Docket No. 5511-18L, all filed 8/5/22.

These look like the Midco type give-and-go, sale of corp with assets worth a ton and basis of bortscht (please pardon obscure technical term) to a shill, which tries a phony dodge to bury the gain when the tax is due. I’ve blogged many such, and in these IRS makes much of transferee liability in tossing the broad-scope OICs at issue.

IRS gets summary J for the NFTLs and NITLs here, and the tossed OICs, but strikes out on Boss Hossery. Straight Michael Corleone classical gambit.

I already cited, in my above-named blogpost, to Judge Holmes’ prescient remarks about Boss Hossery. But here’s the grandpappy of them all; see my blogpost “The Great Dissenter,” 12/28/11. “(T)he silt we stir today will cloud the cases we plunge into tomorrow.”

And STJ N’Yawk Choi looks to be the one selected to clean up the silt.


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