What keeps this aged blogger young is the unwithered by age variety of tax court petitioners’ maneuvers. Here’s two of them.

First, Judge Kashi Way encounters Debra Reed and Timothy Reed, T. C. Memo. 2025-4, filed 1/16/25. Deb had her identity stolen a dozen years ago, which DOJ affirmed. She and Tim claim that’s why it took them four (count ’em, four) years to petition the NOD from their CDP. Of course, Boechler, P. C., opens the doors of The Glasshouse in the City Soon to Experience Governmental Efficiency to belated NOD petitions.

Except here it doesn’t.

“Although not stated succinctly, petitioners’ position is essentially that they were prevented from making a timely Petition because they were victims of identity theft. However, the identity theft occurred in 2012, the DOJ notified petitioners in 2016, and Appeals considered and verified the identity theft in its CDP hearing in 2018 before issuing a Notice of Determination in 2019. Thus, the critical facts which might provide a basis for tolling the limitations period occurred many years before respondent issued the Notice of Determination. Furthermore, the timing of these events does not lend support or provide a basis for the four-year delay between the date of the Notice of Determination and the date petitioners decided to petition this Court.” T. C. Memo.2025-4, at p. 4. (Footnote omitted, but it says pleadings of pro ses like Deb and Tim get liberally construed.).

Next, I want to give some kind of Taishoff award to Cassandra Allen, T. C. Memo. 2025-5, filed 1/16/25. Cassandra has really slipped the surly bonds of the usual. She admits omitting $18K of income from her return, submits another return showing the omitted income but not computing tax due, and finally comes up with a copy of a 1040X amended return showing the $18K as income, but computing the same tax due as shown on the erroneous return that omitted the $18K. When asked why, Cassandra tells Judge Albert G. (“Scholar Al”) Lauber that she paid the extra tax by filing Form 709. Yes, that’s a gift tax return.

IRS wants summary J. “… respondent points out correctly that petitioner has conceded the only remaining issue in this case by submitting a Form 1040–X that reported additional wage income of $18,713 for [year at issue]. That sum matches precisely the $18,713 reported on the Form W–2 supplied by the D.C. Government. Petitioner does not dispute receiving this income, and her concession supplies a factual foundation linking her to the income-producing activity.  Instead, petitioner asserts that her ‘tax liability still remains zero’ because she allegedly reported the additional $18,713 on a Form 709, an assertion we find difficult to understand.” T. C. Memo. 2025-5, at p. 4.

May I suggest that Cassandra may think that reporting the income, in whatever form one does it, is enough, while paying tax on that income is strictly for little people?

IRS gets summary J but is enjoined by Judge Scholar Al to “carefully search petitioner’s accounts for any tax payments she has made toward her [year at issue] income tax liability.” T. C. Memo. 2025-05, at p. 5, while preparing the numbers for the Rule 155 bean count.

Finally, I want to give Roger M. Fredenberg and Kimberly D. Fredenberg, T. C. Sum. Op. 2025-1, filed 1/16/25 a separate entry because of CSTJ Lewis (“It’s That Name Again”) Carluzzo’s observations on reduced rent, repairs, and the “goofy regulation.”