I’m sure Judge Alina I. (“AIM”) Marshall is glad to join in the Psalm 118:15 treatment when Ryan Charles Minnig folds his frivolity, leading off the 2023 memorandum parade with T. C. Memo. 2023-1, filed 1/4/23.

RC was frivoling away with the wages-aren’t-income and no-valid-delegation standard protester jive from SNOD to trial. Whereupon, when Judge AIM cautioned him about the Section 6673 frivolity chop IRS wanted should he continue to frivol, RC, like many another who saw the red laser dot on the seam of their body armor, threw down his weapons.

“Although petitioner did not abandon his frivolous arguments, he was cooperative at trial and worked collaboratively with respondent’s counsel in the stipulation process. He stated: “I certainly don’t want to make any other frivolous points as they’re called, but I’m just trying to do what I think is right and not sort of ruffle any feathers.” T. C. Memo. 2023-1, at p. 3.

Although a simple cite to Crain and Wnuck would be enough for us professionals, Judge AIM provides the usual “somber reasoning and copious citation of precedent” to not sort of ruffle any feathers. And RC, although a second-time loser (see T. C. Memo. 2023-1 at p. 3), avoids the Section 6673 chop.