A couple items (hi, Judge Holmes) from the Glasshouse in the City At the Heart of the Storm.
First, Estate of Anne Milner Fields, Deceased, Bryan K. Milner, Executor, T. C. Memo. 2024-90, filed 11/4/24. And before you yell with one voice, readers, “Wait! Didn’t you cover this case back in September?” yes, I did, but this is a correction. The mathematical anfractuosities adumbrated by Judge Elizabeth A. (“Tex”) Copeland need a Rule 155 beancount to sort them out. Hence. that 9/26/24 opinion is toast, and the current version substituted.
Next, though it often falls to the deceased that they fall “to dumb Forgetfulness the prey,” as a much better writer than I put it, Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan finds anonymity of whistleblowers may vanish at their death. So it may be with Whistleblower 17543-19W Deceased, filed 11/4/24.
“The executrix indicates that she still wishes to proceed anonymously. We will order the executrix to show cause why, following petitioner’s death, we should not modify or lift our order allowing petitioner to proceed anonymously and change the caption of this case to reflect the real names of petitioner and the executrix. See Tax Court Rule 63(a).
“In support of petitioner’s Motion to Proceed Anonymously … petitioner represented that he would face adverse professional consequences if his identity as a whistleblower were revealed. We granted his motion for that reason.” Order, at p. 1. (Citation omitted).
However, anonymity is not perpetual. Circumstances change, but the public’s right to know does not. So let the executrix show cause why the veil must remain undisturbed, and incidentally, what her authority is to act as executrix.
Finally, another stamped approval of change of venue in a Dixieland Boondocker, over IRS’ objection. Here’s Cedar Creek Corner, LLC, Piedmont Private Equity Manager, LLC, Tax Matters Partner, Docket No. 22218-22, changing venue from Birmingham, AL to you-know-where. The tactic marches on? See my blogpost “The Lowest Bidder,” 10/28/24.*
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