No doubt about it, Dennis Lee Simpson is definitely a WFC (Wag First Class). See my blogposts “Sign on the Dotted Line – No,” 1/21/23, and “The IEDs of Tax Court Practice,” 9/12/23.

See also Dennis Lee Simpson, T. C. Memo. 2024-85, filed 9/5/24.

Judge Ronald L. (“Ingenuity”) Buch simultaneously acknowledges Dennis’ canny dodging of the fraud exception to Section 6501 3SOL, incidentally defeating the Section 6651(f) enhanced late filing for fraud add-on, but hoists him with his own petard in proving he never filed for one year at issue. See my blogpost first hereinabove-mentioned, as my high-priced colleagues would say. No 1040, no SOL.

IRS wants to use one or two Dennis’ finger-fehler (hi, Judge Holmes) to cover multiple badges of fraud, but Judge Buch won’t let them. He plays Humphrey Bogart, as IRS’ seven (count ’em, seven) attorneys try to play Alfonso Bedoya, uttering the world-famous line that Bedoya never spoke. IRS doesn’t have enough badges, says Judge Buch. So one of Dennis’ years, and two of his self-settled trust’s, are out, per 3SOL. And the Section 6651(f) fraudulent late filing enhancement is out for everything.

But one year is in, the one for which Dennis established he never filed a return (the one filed in his name he successfully disavowed). So Dennis is drawing dead. He put in no evidence to overturn all the delicts more particularly bounded and described in IRS’ First Amended Answer to Second Amended Petition.

Incidentally, if you’re interested in how those magazine subscription solicitation businesses work, Judge Buch will tell you.