Just about two-and-a-half years ago I predicted that Anthony Aulisio, Jr., T. C. Memo. 2024-29, filed 3/13/24, “(S)hould be quite a trial.” See my blogpost “The Limits of Summary J,” 10/4/20.

Was it ever! AA’s testimony (or testimonies, as they were varied) was definitely self-service, when his amended but unprocessed return for year at issue didn’t contradict him. For some samples see T. C. Memo. 2024-29, at p. 16, footnotes 13 and 14.

And AA’s documentation and substantiation fell far short of convincing Judge Alina I. (“AIM”) Marshall.

I’ll spare you the forty (count ’em, forty) pages of her prose.