The heavy-duty chops amerced upon Raju J. Mukhi, 162 T. C. 8, filed 4/8/24, are not eclipsed by the Eighth Amendment, says Judge Travis A. (“Tag”) Greaves, as said chops are there to protect the public fisc and bring into compliance such as Raju, who stash their cash in “strands afar remote”.

And he gives IRS summary J, sustaining the NOD handed Raju, when his RCP turns out to be a lot more than enough to reject his IA or OICs. And the reference that SO3 made at the CDP to the memo AO prepared at postassessment review isn’t sufficient to contaminate the CDP with prohibited prior involvement, or make the AO the de facto reviewer at the CDP.

Incidentally, Raju copped to ” one count of subscribing to false U.S. individual income tax returns and one count of failure to file an FBAR. The plea agreement expressly stated that it did not limit the rights of the U.S. Government to take any civil or administrative actions against petitioner, except as agreed regarding civil liability for failure to file an FBAR.” 162 T. C. 8, at p. 2.

So Raju is down on chops for his Section 6677 failure to file information returns on his offshoring. And Raju also violated Section 6038(b)(1) foreign corp reporting.

Except.

IRS is without statutory jurisdiction to collect Section 6038(b) chops. See Fahmy, 160 T. C. 6, filed 4/3/23. For the Fahmy story, see my blogpost “Nor Assessable,” of even date therewith. IRS asks Judge Tag Greaves to toss Fahmy, but he won’t. First, though Fahmy is on appeal to DC Cir, he asked the parties to brief the impact thereof, and they didn’t. Second, Raju is a MO resident, and thus is Golsenized to 8 Cir, which has said nothing about the issue, so Tax Court can go with its own precedents.

Summary J, and a Taishoff “Good Job,” for Raju’s trusty attorneys on the 6038(b) chops.

Taishoff says once again, our ridiculous Circuit Court appellate system for the national statute that impacts more citizens than any other exalts Rare Noodledom.