Those fortunate enough to be at liberty yesterday noontime heard from six (count ’em, six) Chief Judges, past and present, of United States Tax Court. They spoke of early trailblazing (race, gender), of seemingly wild predictions of future technology that came true, of fleeing from the collapse of the Twin Towers and later piloting the Court through the COVID lockdown, and the launch of DAWSON…a remarkable anabasis to match any account, ancient or modern, of an expedition into a new country.

I am sure that the now-complete 19-member bench, not to mention the extraordinary lineup of Senior Judges and STJs, could tell of events of like tenor.

But that was yesterday. Today, Judge Adam B. (“Sport”) Landy, the only STJ in modern times to advance from thence to the Big Bench in the “Small Court”, returns to utterly mundane duties, of the sort usually encountered by kindergarten teachers.

It ought not to require one who has earned a Bachelor of Science in Chemistry and a Master of Science in Sport and Entertainment Management from the University of South Carolina, a Juris Doctor from the University of South Carolina School of Law, and a Master of Laws in Taxation from the Northwestern University Pritzker School of Law, to instruct IRS’ counsel thus.

“(T)he Commissioner filed a Notice of Filing of the Administrative Record, Certificate as to the Genuineness of the Administrative Record, and the Administrative Record. The Administrative Record fails to provide page numbers or be identified by Bates numbering for each exhibit. Therefore, we will order the Commissioner to refile the Administrative Record specifically marking each exhibit with the proper exhibit designation (i.e., 1-J, 2-J, etc.) and page number (i.e., Page 1 of the total number of pages, Page 2, etc.) or by Bates number.” Order, at p. 1.

The case is William H. Wooten and Shannon J. Wooten, Docket No. 1719-24L, filed 112/22/24. I note that a quick docket peek shows four (count ’em, four) attorneys appearing for IRS. One would think that perhaps one of them…but enough.