Of whom else might that phrase be spoken than Judge David Gustafson? No one, I fear.

Today’s object of Judge David Gustafson’s guided largesse is Vitaly Nikolaevich Baturin, Docket No. 14796-14, filed 12/26/24. All y’all will recall VitNik’s nuclear tour de force, which led to his encounter with the US-Russian Federation Tax Treaty.

What, no? Then see my blogpost “A Bad Day for the Russians,” 4/8/22*.

Well, the trial 4 Cir wanted still hasn’t happened. IRS wants summary J (what else is new?), but VitNik, despite ten (count ’em, ten) years of litigation experience, still wants Judge David Gustafson to cut him come slack.

This Judge David Gustafson does. VitNik has five (count ’em, five) questions how to deal with an IRS summary J motion. And as befits a nuclear scientist, they are material, direct, and nonfrivolous.

If one approaches Judge David Gustafson thus, he’s obliging to a fault. He gives VitNik the Isaiah 42:3 treatment.

If you’re looking at an IRS summary J motion, check out Judge David Gustafson’s explication, even if you have more than ten years’ litigation experience.

* https://taishofflaw.com/2022/04/08/a-bad-day-for-the-russians/