Maybe most lawyers can’t add, but not Judge Tamara W. (“Math Whiz”) Ashford. My offer of proof in substantiation of the foregoing is Leon A. Greenblatt III and Leslie N. Jabine Greenblatt, T. C. Memo. 2024-109, filed 12/16/24.

This is a multi-decade, multi-corporate joust over $36 million in NOL carryforwards, unreported income, and Section 351 corporate give-and-gos, which go off largely on want of substantiation.  Takeaway- Packrats win; save every scrap of paper. Back up your harddrives. Put a litigation hold on everything.

Leon left too much to his ex-partner, but the ex hired a topnotch CPA and gave him all the stuff he asked for, thus saving Leon from massive chops.

It’s entirely too fact-based to paraphrase or abstract, but Judge Ashford stays with it. If you’ve got a tangled twenty-plus-year NOL, Judge Ashford has written an essay here on how to unscramble it.