A couple orders (hi, Judge Holmes) caught my eye today, each too small to warrant a full-dress post.

First up, Estate of Pearl B. Kalikow, Deceased, Eugene Shalik, Executor & Edward M. Kalikow & Laurie K. Platt, Limited Administrators, Petitioners, Docket No. 14436-10, filed 10/24/23. Final deficiency in estate tax $3,653,939.00. Hopefully somebody deposited enough to stop interest running; with a thirteen-year-old docket number, you could get an eight-figure bill. For the backstory, see my blogpost “Where There’s a Will,” 2/27/23.

Next, Steven Feller & Louise Feller, Docket No. 11581-20, filed 10/24/23. Backstory in my blogpost “Positively Farcical,” 8/2/23.  I won’t weary my readers with yet another discovery joust. Only one point: Steve & Louise sold the Sub S wherefrom they took the Qualified Research Credits at issue, and say they have none of the paperwork IRS wants (and it’s bagsful). The new owner has it all. Taishoff says that’s SOP when you buy a business. However, “Petitioners note that the current owner of Feller PE [the Sub S] expressed a ‘willingness to make his team and the records available to assist both parties with this case, and to meet their burden and to save judicial resources and costs.’

“The record does not indicate whether petitioners have worked with Feller PE to obtain respondent’s requested documents.” Order, at p. 2.

Judge Christian N. (“Speedy”) Weiler, currently the discovery guy, says not having documents IRS reasonably wants is an excuse only when the documents are destroyed or in hostile hands. So get them from your obliging buyer. That saves third-party subpoenas.

Finally, Pradeep Kumar Xplorer, Docket No. 15791-23, filed 10/24/23, objects to having his case dismissed for duplication with another case dismissed for duplication with a third case. Xplorer’s problem is he can’t find the NOD from the CDP he’s petitioning. So he wants Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan to find it for him, as “your tax court will have easy access to it.” Order, at p. 2. And while Ch J TBS is at it, would she contact Xplorer’s ex-wife, with whom he’s had no contact since 2007, and ask her to phone him (number supplied). Order, at p. 1, footnote 2.

Ya can’t make this stuff up.

Ch J TBS tells Xplorer he has BoP: no NOD, no case. And his requests are frivolous, so he can lose his e-filing privileges if he persists.