CSTJ Lewis (“He Doesn’t Only Spell It Right, He Gets it Right”) Carluzzo is not one to be hindered by trifles. CSTJ Lew is strictly a “bottom line” kind of jurist, one after the heart of the late Judge Richard Posner of 7 Cir.

Judge Posner issued the famous statement: “I pay very little attention to legal rules, statutes, constitutional provisions. … A case is just a dispute. The first thing you do is ask yourself—forget about the law—what is a sensible resolution of this dispute?” This from the most-quoted (as of 2021) American legal scholar.

CSTJ Lew is on the case in Timothy R. Taylor, Deceased, Sally Ann Taylor, Successor in Interest, and Sally R. Taylor, Docket No. 16843-23S, filed 12/9/24.

I’ll quote CSTJ Lew. “The caption in the Proposed Stipulated Decision… is incorrect, and the document is otherwise not properly signed. For those reasons, it is ORDERED that the document is stricken.” Order, at p. 1.

Now most Judges, sticklers for form, would leave it at that, do the kindergarten teacher approach, and send the parties back to get it right, and resubmit.

Not CSTJ Lew. This is United States Tax Court, constituted pursuant to the Constitution of the United States, Article I, Section 8, clause 9, by Act of Congress duly enacted, not Ding Dong School.

“To give effect to the basis of settlement reflected in the stricken document it is further ORDERED and DECIDED that there is a $4,015 deficiency in petitioners’ 2021 federal income tax.” Order, at p. 1.

My kind of judge: stipulate or don’t stipulate, just capitulate.