However white your shoes (and those of the trusty attorneys for Ranch Springs, LLC, Ranch Springs Investors, LLC, Tax Matters Partner, Docket No. 11794-21, filed 6/11/24, couldn’t be whiter), the basics still apply when you’re moving to exclude proffered evidence.

First, they seek to preclude any evidence “relating to the activities ‘of non-Petitioner entities and other conservation-easement donations.’” Order, at p. 1.

Like what? asks Judge Albert G. (“Scholar Al”) Lauber. Movant has to identify what documents they want out. Failing which, they have objections at trial on whatever grounds the law permits to stifle any irrelevant or impermissibly injurious evidence.

Next, the trusty attorneys want to preclude the expert’s report of IRS’ employed expert. We’ve seen before that this doesn’t work, if the expert is an expert and the report meets the Rule 143(g) checklist. IRS’ expert has been recognized before, and has stated his credentials per Rule 143(g)(1)(D), so the report goes in, but the expert is subject to cross-examination. That entails all the “hired-gun” and “Made As Instructed” lines of attack on credibility and weight of the expert’s report and testimony.

Basics, basics. All of us, novice and old-greyback-from-Wayback, need to remember.