Section 6751(b), the famous Boss Hoss chickenscratch delivered whenever, is a gift that never stops giving. Ever since Chai, the fight over when said chickenscratch need be obtained has embroiled the CCAs and kept Tax Court forever on the twinkle.

And the Dixieland Boondockery tsunami has added the partial summary J for chops both simple and enhanced to the menu.

Necessity is the mother of cliché, and this red-hot Mama has given birth to the implacable scorched-Boondocks defensive style of such as Vivian D. Hoard, Esq. Ms. H. exhibits a fighting spirit that evokes admiration in Dorchester Farms Property, LLC, Dorchester Farms Manager, LLC, Tax Matters Partner, T. C. Memo. 2023-93, filed 7/24/23.

Judge Albert G. (“Scholar Al”) Lauber must yearn for the calm of Hatchard’s of  Petty Curry at dear old Cambridge (and luncheon at the Garden Inn; yes, I’ll have just a spot more of the Old Landed), as Ms. H. delves into the deep background of who suggested what to whom, and who supervised, and when supervisory authority ceased. Confronted with six (count ’em, six) OCC minions, and with but a single associate, Ms. H. turns Liberty County, Georgia, into the French Foreign Legion at Camarone, and earns a Taishoff “Good Try, First Class.”

All Judge Scholar Al can do is riposte with “but the chickenscratch.”

Of course, lost in this farrago is the real issue: Is Exam brandishing chops to bludgeon settlements out of terrified taxpayers with meritorious claims they cannot afford to pursue?