Classicist Judge Patrick J. (“Scholar at”) Urda disproves a classic mantra of mine in Thomas W. Langlois, T. C. Memo 2025-12, filed 2/3/25, and showing off his Latin erudition in a footnote. And more.

The footnote bears the title first set forth hereinabove at the head hereof, as my expensively prolix colleagues would say.

Here it is, in extenso.

“Ecce math. Mr. Langlois contended that he made capital contributions of $59,309 in 2012; removing the Form 1099 category reduces this amount to $49,917. After we take into account his 2012 distributive share of loss from Hair Station ($32,636), he is left with an adjusted basis of $17,281. For 2013 the removal of the Form 1099 category reduced his claimed capital contributions from $55,925 to $20,342. Adding his 2012 basis to his 2013 contributions yields $37,623, which is less than the distributive share of loss he claimed for 2013 ($40,309) and left him with an adjusted basis of zero (and a surplus loss of $2,686). Things continued along this path in 2014, which saw a reduction in his contributions to $20,793, well below the sum of the carryforward loss from 2013 ($2,686) and the distributive share of the 2014 loss he claimed ($38,569), which left him with an adjusted basis again of zero and a loss of $20,462 to be carried forward. Even assuming that Mr. Langlois made capital contributions of $15,189 in 2015 as he asserts, he has an insufficient basis—in light of the loss carryforward of $20,462—to deduct the distributive share of loss claimed on his 2015 tax return ($29,537).” T. C. Memo. 2025-12, at p. 16, footnote 7.

Judge Scholar Pat is a lawyer who can add.