For those keeping score at home, we have reached Docket No. 19279-23, as at 12/6/23.  At the current rate of filing, we can expect further 1500 petitions through 12/31/23. The tsunamis of previous years, when 35,000 petitions were filed in a single year, are now of interest only to historians. And of this year’s crop of 20,000 petitions, fewer than one in a hundred will result in a T. C. Memo. Barely one in 600 will feature in a T. C. Sum. Op.

So don’t be surprised, dear reader, when there are days with nothing new in United States Tax Court,