Cold print, especially word-processor-generated print, cannot begin to express the depth of contempt and summary dismissal conveyed by the somewhat-arcane phrase first set forth at the head hereof (as my expensive colleagues would say). It was Grandma’s way of blowing off one who held himself (it was always “himself” in those days) out as an expert, but was in fact a poseur, a mere smatterer, unworthy of the slightest consideration.

Andrew P. Mattson & Lindsey J. Mattson, Docket No, 6501-20, filed 10/4/24, were caught up in the Pine Ridge hush-hush Aussie outback kerfuffle. For the backstory, see my blogpost “Pine Ridge – Case Closed,” 11/20/23*. Among the cases therein cited is that of Cory Smith, who appealed the toss of his case to DC Cir.

That appeal caused Judge Ronald L. (“Ingenuity”) Buch to put Andy’s & Lindsey’s motion for reconsideration on hold, pending outcome of said appeal. But Cory’s former attorney pulled out, and his successor moved to withdraw the appeal.

Judge Ingenuity Buch tells us why, and why the other outback spies-in-the-sky might wish to bail.

“Counsel confirmed that the positions argued in Smith’s briefing, which are also advanced in several cases pending before the Tax Court, were proposed to Smith by John Anthony Castro, a tax preparer recently convicted of 33 counts of federal tax fraud.” Order, at p. 1.

Looks like Mr. Castro “marketed himself to U.S. taxpayers around the world, including by ‘claiming to be an expert on certain tax issues related to Australian ex-pats,’ and advised clients to take nonexistent exclusions based on his interpretation of tax treaties between the United States and Australia).” Order, at p. 2.

Cory Smith disavows the bogus assertions he got from Mr. Castro, and says he only appealed because he promised to pay Mr. Castro half the refund he got from the US fisc if he won. Looks like Mr. Castro didn’t care much for the law or regulations.

Motion for reconsideration denied.

* https://taishofflaw.com/2023/11/20/pine-ridge-case-closed/