The APA-based attack on Notice 2007-19, 2007-1 C.B 689, goes on apace, but Judge Patrick J.(“Scholar Pat”) Urda has the canned order in hand, opens and serves it up cold to Herbert Hirsch & Bonita Hirsch, et al., Docket No. 28898-10, filed 6/20/23.

It’s a replay of my blogpost “Oodles of Cases,” 6/16/23. And, of course, Herb & Bonita are represented by the same attorney as in the aforementioned blogpost, whom I’ll call JDIII.

Judge Scholar Pat cannot resist referring again to the “oodles of cases” wherein IRS refused to grant free-fire status to well-heeled believers that they are Virgin (Islanders), Order, at p. 3. And he has somber reasoning to go along with the copious citation of precedent.

More to come, I do not doubt.