Well, not enough people did, because he went broke. But his nonexistent bookkeeping and sketchy cooperation with IRS nearly got him a bushelbasket of unreporteds with Section 6663 fraud chops at no extra charge, until to the rescue drove Judge Elizabeth A. (“Tex”) Copeland.

You can read the story of Jesse Alvarado and Estate of Maria de Lourdes Velasquez, Deceased, Jesse Alvarado, Special Administrator, T. C. Memo. 2024-1, filed 1/3/24. The estate of the late Maria de Lourdes is stiped out per Section 6015 innocent spousery. Judge Tex Copeland takes IRS’ bank depositry and Cohanizes like a 2023 Dodge Challenger Hellcat SVT with the 6.2 hemi for only $76K (381 original miles).

When it comes to sorting out auction prices, finance company holdbacks and chargebacks, matching VINs to vans, and bearing heavily while giving Jesse the benefit of doubt due someone who “held a PTIN and prepared returns for some other taxpayers, and … was a commercial lender at Comerica Bank for over two decades.” T. C. 2024-1, at p. 23, Judge Tex Copeland is a grand master.

Judge Tex Copeland acquits Jesse of fraudulent intent. “However, a trained tax professional in Mr. Alvarado’s presumptive position—that is, palpably suffering business losses but  devoid of the records to prove it—reasonably could have believed his business would not have tax liabilities for the years in issue.” T. C. Memo. 2-24-1, at pp. 23-24. Tax pros are some of the worst at keeping their own records; shoemakers’ children never have clichés.

Jesse does owe the recomputed deficiencies, plus negligence chops and the late-filing add-on.

But when you read her opinion, and eyeball the 20 (count ’em, 20, and I have) pages of appendix, I venture to guess that you’ll agree with me that you might just maybe so buy a used car from Judge Tex Copeland.