Judge James S. (“Big Jim”) Halpern has obviously read Judge Cary Douglas Pugh’s nanopinion in Englert, T. C. Memo. 2023-38, filed 3/22/23, because he cites it in Ryan Lance MacCubbin, Docket No. 15352-22, filed 4/18/24, Transcript, at p. 6.

But as I said when Judge Pugh’s four-page opinion was first published, it was a template for the entire Bench when confronted by the all-zeroes, my-wages-aren’t-taxable jive. See my blogpost “The Shortest Way With Dissenters – Part Deux,” 3/22/23.

Why did Judge Halpern need ten (count ’em, ten) pages to send off Ryan for trying the same stunt? As Judge Big Jim remarked, “The parties have stipulated that, during [year at issue], petitioner worked at C and received from C earnings of $51,007. There is little more to consider.” Transcript, at p. 6. (Name omitted).