There’s another addition to the “can’t add” category. Lawrence Leroy Henry, Docket No. 24155-18, filed 2/14/25, is doing a Rule 155 computation after Judge Gustafson disposed of his “anyway expenses,” for which see my blogpost thus entitled.*
LL was told to stick to the arithmetic and leave the argument behind. “Consequently, any submission that petitioner makes should not point out errors in the Court’s opinion but only errors in the Commissioner’s computation.” Order, at p. 1.
IRS weighs in, but unhappily, LL tries again.
“The biggest difference between petitioner’s computation and the Commissioner’s is that petitioner argues that he is entitled to more than $1 million of ‘Savvy Bill Pay’ deductions that we expressly disallowed. On a smaller scale, he grants himself amounts of other deductions greater than our opinion held. He grants himself other categories of deductions about which our opinion was silent–and about which his own post-trial brief was silent. His computation is not compliant with Rule 155, does not effectuate our opinion, and is not helpful. We will instead follow the Commissioner’s computation and enter decision in accordance with his proposal.” Order, at p. 2.
Taishoff Law 