I’ll use this heading from time to time to note in brief Tax Court opinions and orders that don’t merit a complete entry on their own account

First up, Robert A. Di Giorgio, Sr., T. C. Memo. 2023-44, filed 3/29/23. Rob is a mortgage and real estate wheeler-dealer, whose underreporting gets him deficiencies and chops north of $10 million, but get the second Ms. Di Giorgio, a Philippine national with minimal education, innocent spousery. Nothing novel here.

Next, John Landis Heinaman, Docket No. 11263-21L, filed 3/29/23. John is nailed for TFRPs for Heinaman Contract Glazing, Inc., for which he is a responsible person.

The only interesting thing in this off-the-bencher from Judge Goeke is that, notwithstanding telling John he has already had his chance at Appeals to contest liability and lost, thus taking liability off the menu, Judge Goeke lets him testify about liability on the trial. He admits paying creditors before paying IRS, Transcript, at p. 14.

“So despite the fact that the underlying liability is not before this Court, we note that petitioner’s position regarding the underlying liability is flawed.” Transcript, at p. 14.

And John was less than candid about his available assets when he applied for an OIC.