I don’t know if Judge Ronald L. (“Ingenuity”) Buch is a fan of old showtunes, or if he remembers hearing the Jerome Kern – Dorothy Fields classic upon which I based my title above set forth. I expect he was too busy pursuing his illustrious academic and professional careers to bother with such trivia (not to say frivolities).

Nevertheless, if Tax Court Judges and STJs need an anthem, I suggest the above aforementioned as a title to the Rule 155 gavotte.

Judge Buch reprises Kristen L. Quevy, T. C. Sum. Op. 2023-34, corrected version filed 12/19/23. While IRS still wins, they can’t get an outright confirmance of the SNOD, because there were a couple concessions (hi, Judge Holmes).

So instead of decision for IRS, we have “decision will be entered under Rule 155.” T. C. Sum Op. 2023-34, at p. 7.

Da capo.