I didn’t blog John Thomas Minemyer, T. C. Memo. 2020-99, filed 7/1/20 when it came out; it was just another blown Boss Hoss (mention of fraud penalty before Boss Hoss sign-off). But then 10 Cir filled the inside straight that 9 Cir and the Elevenses are playing, picking up on Kroner and Laidlaw’s Harley Davidson (whenever, as long as supe is still supe). 10 Cir affirmed the deficiencies but reversed on the chops, reinstating same per ex-Ch J. Michael B (“Iron Mike”) Thornton’s monumental dictionary chaw (see my blogpost “Money-Back Guarantee Meets the Boss Hoss,” 11/30/16).

Judge David Gustafson and I ain’t doin’ so well.

So Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan has to decide if civil fraud chops should be applied to JT’s offshoring of substantial cash from his underground activities (his partnership sold “a molded polymer coupler—a device that connects pipes that hold underground fiber optic cables—to the telecommunications industry.”). T. C. Memo. 2023-149, filed 12/13/23, at p. 2.

JT ran cash through Malaysia and Nevis (a charming island; the old sugarcane steam train ride is fun), and ultimately pled out in USDCDCO to one count of tax evasion.

Ch J TBS finds JT understated, underpaid, concealed, gave implausible and inconsistent statements, filed false returns, and pled to tax evasion, a criminal offense. Enough badges of fraud for Eagle Scout.

Section 6751(b) is the Dead Hoss.