It must be vacay time in Our Nation’s Capital, because no opinions from Tax Court today. But the hardlaboring clerks and flailing datestampers are going all out, as the paper and electrons keep flying.

North Donald LA Property, LLC, North Donald LA Investors, LLC, Tax Matters Partner, Docket No. 24703-21, filed 7/12/24 but served today, has unleashed a barrage of expert reports worthy of the pen of a Francis Scott Key. Judge Albert G. (“Scholar Al”) Lauber has generously lodged them all at the Glasshouse Guest House.

Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan is less hospitable toward Marsha Francina Constantine, Docket No. 9722-24, filed 7/15/24. Marsha Francina wants to file a CPAF, which Ch J TBS says is mistitled, and a Certificate of Service of Motion for an Order under Federal Rule of Evidence 502(d), likewise misnamed. Ch J TBS says these are Exhibits, and Marsha Francina should talk to IRS’ counsel, whose identity and whereabouts will be made plain when IRS counsel answers her petition, due by 8/16/24. Meantime, their fate is unknown.

But not so Marsha Francina’s separate Motion for an Order under Federal Rule of Evidence 502(d) and a Motion to Enforce a Refund of Overpayment Pursuant to Rule 260 that appear to be the same document filed as a Civil Penalty Approval Form. Those get tossed.

In another development, discussion is starting up on IRS’ settlement offer for non-petitioned SCEs (that’s taxspeak for Dixieland Boondockery). My colleague Peter Reilly CPA thinks it’s a sweet deal; I think there’s a thorn or two amongst the proffered roses. I do hope IRS publishes a Notice as to how successful the program is when the results starting coming in. The proof of the pudding, and all that.