Please excuse execrable pun (sorry, guys, the devil made me do it), but the trusty attorneys for I-20 Oconee, LLC, I-20 Oconee Limited, LLC, Tax Matters Partner, Docket No. 12663-21, filed 4/30/24, get a Taishoff “Good Try, First Class,” even as Judge Elizabeth Crewson Paris gives IRS summary J on the Boss Hossery in their Dixieland Boondockery.

It’s all the usual suspects, Belair, Raifman, Palmolive, and a bunch others (hi, Judge Holmes), all (or almost all) of which I’ve blogged, so I won’t waste time citing to them. “Personally approved” means what?

According to well-settled Tax Court precedent, just “OK.”

Said trusty attorneys aren’t buying, and apparently they have clients willing to call. As usual, the story is in a footnote.

“Petitioner’s Response to Respondent’s Motion for Summary Judgment… states that ‘Petitioner understands the Tax Court’s applicable precedent does not require Respondent establish a certain level of review to satisfy [section 6751(b)(1)].’ Therefore, petitioner ‘opposes Respondent’s Motion solely to preserve its position on appeal that a mere rubber-stamping of a penalty determination is not sufficient to constitute a “personal” review.’” Order, at pp. 3-4, footnote 4.

Of course, the I-20s are Golsenized to 11 Cir, the Circuit that gave us Hewitt. Cain’t hardly wait for the appeal. Maybe a Section 7482(a)(2(A) interlocutory?

Edited to add, 4/30/24: A word with one of I-20’s trusty attorneys reminded me that they had tried the Section 7482(a)(2)(A) route four (count ’em, four) years ago, and Judge Albert G. (“Scholar Al”) Lauber slammed the door on them. The trusty attorney was too well-bred to ask if I bothered to read my own blog, but I have, and here’s the story. See my blogpost “Chops Aren’t Ultimate,” 3/20/20.