One might hardly believe that a barren waste of Australian scrubland could furnish forth such abundance of blogfodder, but the hush-hush Pine Ridge joint US-Australian defense installation has done just that. See my blogposts “A Town Like Alice,” 1/12/23, “Not Even His Hairdresser Knows For Sure – Part Deux,” 6/8/23, and “I’ve Heard That Song Before,” 10/30/23.

Seems like the Raytheon braintrusters while away their time on-station thinking up ways to avoid the Section 7122 closing agreements they signed, and parse obscure tax treaties, to try to get Section 911 foreign earned income credits, while Tax Court Judges employ scarce judicial resources to thwart them.

Today, we have Andrew P. Mattson & Lindsey J. Mattson, Docket No. 6501-20, filed 11/20/23. Judge Ronald L. (“Ingenuity”) Buch need expend little ingenuity.

If you’re intrigued by the history of US-Australian tax treaties, see Order, at pp. 4-5.

Judge Ingenuity Buch has this to say about the closing agreement.

“The Mattsons filed a Motion for Partial Summary Judgment on the validity of the Closing Agreement they entered into with the Commissioner. Most arguments the Mattsons raise have been directly addressed in one or more of several cases addressing nearly identical motions premised on nearly identical facts. See Smith. 159 T.C. 33, Henaire, T.C. Memo. 2023-131, and Baney v. United States, 2023 WL 6564028. For the same reasons enunciated in these other cases, we will deny the Mattsons’ motion.” Order, at p. 6.

Baney is a USCFC case, so I didn’t blog it, but if you must have it, here it is, sans Taishoff gloss; it’s much of a muchness. Henaire and Smith are covered in my above-cited blogposts.