That’s how long I’ve been following the saga of Scott A. Blum and Audrey R. Blum, T. C. Memo. 2025-18, filed 2/18/25. I’ve paid good money for whiskey younger than this case. But Judge Goeke is shooting down the last-ditch efforts of the latest of Scott’s trusty attorneys to avoid the massive whack resulting from the collapse of Scott’s attempts at shelter.

This one involves whether the FPAA was sent to the right address. Spoiler alert- Judge Goeke finds it was.

You can read the 48 (count ’em, 48) pages of Judge Goeke’s trudge through history.

I tried, but failed.

If you’re short of eye-glaze, try this: “DSIF’s BMFOLV transcript shows that the IRS audited DSIF’s return for the 1999 taxable year and that the IRS removed the records relating to the audit from its active business master file (BMF) to its recoverable retention register (RRR) in 2014. The IRS moves taxpayer records for older, inactive tax periods to the RRR, but the records can be restored to active status if they are needed. See IRM 4.4.23.8.1 (Aug. 7, 2013). The files in the RRR are less accessible but can be returned to active status in the BMF if they are needed. The 2014 removal of DSIF’s files to the RRR coincides with the district court’s 2014 order granting summary judgment to the Government in the 63 SIFs case. There is no indication or evidence that removal of DSIF’s files to the RRR means that petitioners settled their tax liability attributable to the BLIPS tax shelter. It makes sense to us that the IRS moved DSIF’s records to the RRR when the 63 SIFs case ended because partnership-level records are not generally required to make affected item adjustments at the partner level.” T. C. Memo. 2025-18, at p. 42.

The Section 6662(h) 40% chop is a partnership item, so Judge Goeke has no jurisdiction to decide Scott’s trusty attorneys’ bœuf thereover. Whatever flaws are alleged in IRS’ paperwork is not for Tax Court to decide. See Section § 6230(a)(2)(A)(i).