Translated from the language of textonics, shaking my head yet again. Mark G. Strom, T. C. Memo. 2024-58, filed 5/16/24, MD and MBA, with an illustrious resumé and eight-figure net worth, laments that he has run up an 83 (or maybe 84) million dollar tax bill (chops and interest included) fighting over wife Bernee’s $100 million stock options that went poof with dot.com. T. C. Memo. 2024-58, at p. 61.

Tough, says Judge Gale. “It may be the case that the Stroms do not have the means to pay the entire tax liability. However, that is not the proper inquiry. Rather, the question before the Court is whether, after paying his reasonable living expenses, Dr. Strom can pay any portion of the joint tax liability for 2000.” T. C. Memo. 2024-58, at p. 62.

Dr. Strom wants innocent spousery. But he knew all about the stock options (ignorance of tax consequences doesn’t count, as that would be ignorance of the law, the ultimate nonstarter) and the warnings from high-priced counsel that, at best, he had “reasonable basis” for the position he and Bernee reported on their 8275 (the “please audit me” form). “Reasonable basis” may spare some chops, at best.

But the e-mails, the draft documents, the proceedings in USDCWDWA and appeal to 9 Cir (who really socked it to Dr. Strom), the untangling of bank statements, the catalogue of Saint Lucia international business corporations and AK asset-protection trusts, all set forth in extenso by Judge Gale in 75 (count ’em, 75) pages, makes me wonder why Dr. Strom kept fighting for 20 years while the interest clock kept ticking.

Even his own experts told him it was an uphill fight.

Every strategy but an exit strategy.