Judge Nega gives IRS summary J tossing both of his last blows, thereby bringing to an end the ten (count ’em, ten) year saga of Estate of Joseph A. Insinga, Deceased, By Amanda Gilmore, Personal Representative, Docket No. 9011-13W, filed 12/5/23. The case outlasted Fighting Joe, but his memory will be fresh in these columns, as he furnished no fewer than 18 (count ’em, 18) blogposts.

The OS bucked Fighting Joe’s materials over to Exam, which was already pursuing the targets. Fighting Joe’s stuff and a face-to-face with IRS’ sleuths only confirmed the economic substance tack they’d already taken.

“The administrative record in this case amply supports the WBO’s ultimate findings that: (1) the issues identified in petitioner’s claim were already known to the examination teams, (2) the examination teams made the same adjustments after petitioner’s claim that they were planning to make before petitioner’s claim; and (3) petitioner’s claim information did not lead to any additional adjustments being made.

“Put another way, the WBO found (and the record so supports) that the IRS did not proceed based on petitioner’s information because petitioner’s information did not substantially contribute to any IRS action.” Order, at p. 20.

I wish Judge Nega had given Fighting Joe a T. C. Memo. rather than an undesignated order. It’s a paltry send-off; his memory deserves better.