Once again, I resort to lingo of the opposable-thumbed virtuosi, they who transmit whole volumes of stuff by thumbs alone, while hanging from subway straps and holding their smartphones at impossible angles. For the traditionally-handed, that means “shaking my head.”

Paul C. Robinson, T. C. Memo. 2023-147, filed 12/11/23, has run up three (count ’em, three) years’ worth of deficiencies aggregating $41K plus the Section 6662(a) five-and-ten substantial understatement chops. Paul folds the deficiencies post-trial, but wants to contest the chops.

However,  Paul put in no evidence on the trial of substantial authority, disclosed facts and reasonable basis, or reasonable cause and good faith. And Paul files no opening brief, so is barred from filing a post-trial brief.

Judge Courtney D (“CD”) Jones had already given Paul a chance to file.

Unless the size of the deficiencies militates against negotiating (doubtful), or unless Paul played games (and a docket search reveals nothing more than ordinary pro se ineptitude), I don’t see why it needed three (count ’em, three) lawyers for IRS to deal with this case.