STJ Peter J. (“HB”) Panuthos has six decades of top-class experience as attorney and STJ. But when I find STJ Panuthos confronted by such as Tonia L. Hartman, Docket 1713-24, filed 10/2/24, I am reminded of a line from Nobel Laureate R. A. Zimmerman: “Twenty years of schoolin’ and they put you on the day shift.”

It’s another all-zeros Form 1040. I understand the frustrations and anger; the present system is deeply flawed. But the cure is not effected by making a fruitless protest that only worsens your situation by invoking Section 6673, although STJ Panuthos spares the rod this time.

So STJ Panuthos, ostensibly avoiding “somber reasoning and copious citation of precedent” does exactly that. And at close of play, “… here the record demonstrates that, whether focusing on the invalidity of petitioner’s return reflecting zero income… or the computational amount of income omitted, the statute of limitations does not bar assessment of petitioner’s [year at issue] taxes.” Order, at p. 4. (Citations omitted).

Plus five-and-ten chop, of course.

But is a law review article by a distinguished attorney going to convince such as Tonia?