Not to be outdone by Judge Pugh, who just mulcted Lou & Dawn Giannini a grand for frivolizing (see my blogpost “A Section 6673 Template,” of even date herewith, as my expensive colleagues say), Judge Christian N. (“Speedy”) Weiler raises to $5K for second-offenders Arlin G. Hatfield III and Jennifer W. Hatfield, T. C. Memo. 2023-93, filed 7/24/23.

That’s Doc Arlin the radiologist, and unlike Dawn the investment specialist who omitted just $100K of income, Doc Arlin the radiologist left out $300K. Both, of course, omitted no frivolity.

Doc Arlin the radiologist’s last outing was T. C. Memo. 2022-59, aff’d w/o op. by 5 Cir. I didn’t blog the case; apparently 5 Cir didn’t find it interesting enough to write about it either.

But it serves as the predicate warning for the Section 6673 chop.

Maybe somebody does read this blog, maybe so.