I don’t know if Tax Court Judges or STJs wish they could do a Defoe when confronted with an IRS summary J motion from a protester CDP. STJ Diana L (“The Taxpayer’s Friend”) Leyden expends seven (count ’em, seven) pages of “somber reasoning and copious citation of precedent” to see off John Evangelista Trapasso, Docket No. 7739-20SL, filed 9/15/22. While a number of paragraphs must have been cut-and-pastes, there’s enough hand-tailoring to show STJ Di read the file. I would expect nothing less.

But I must again lament the waste of scarce judicial resources on a Form 4852 attempted rewrite of a W-2. Filing a baseless Form 4852 rewrite should be good for an automatic $5K chop, although it isn’t.

STJ Di does show John Evangelista a Section 6673 yellow card.