Clark J. Gebman and Rebecca Gebman, T. C. Memo. 2025-36, filed 4/17/25, scarcely merit the seven (count ’em, seven) pages of text, to say nothing of legal acumen, Judge Albert G. (“Scholar Al”) Lauber expends sending them off and sustaining Appeals’ NOD.

Clark and Rebecca have one merit: they’ve furnished me with beaucoup blogfodder. See my blogposts “No Good Deed,” 5/5/17; “No Good Deed – Redux,” 9/18/17; “Can’t Help Lovin’ That Man,” 9/6/18; and “We’ve All Had Clients,” 1/2/20.

But though Rebecca is still a lawyer in Our Fair State, her drafting skills are somewhat less than perfect.

“Petitioners’ pleadings are not a model of clarity, and it is unclear whether they continue to advance a claim to “innocent spouse” relief. In our 2020 opinion we held that Mrs. Gebman was not entitled to such relief for any of the tax years at issue. See Gebman, 119 T.C.M. (CCH) at 1004–05. In any event, the SO repeatedly told petitioners that they needed to submit Form 8857 if they requested such relief, but they never submitted that Form. See Treas. Reg. § 301.6330-1(f)(2), Q&A-F3 (‘An issue is not properly raised . . . if consideration is requested but the taxpayer fails to present to Appeals any evidence with respect to that issue after being given a reasonable opportunity to [do so].’). As a result, no ‘innocent spouse’ claim is properly before us.” T. C. Memo 2025-36, at p. 3, footnote 2.

IRS moves for, and gets, summary J. No Form 8857, no Form 433-A, no Form 656 with deposit, despite SO asking for all thereof.

“In their Response to the Motion for Summary Judgment, petitioners appear to make an offer to compromise the tax liabilities at issue. Any such offer must be submitted to the IRS, not to this Court.” T. C. Memo. 2025-36, at p. 7.

I expect they’ll appeal to 2 Cir, but it’s probably the end of the road. And after they caused a lot of grief for my esteemed colleague The Great Chieftain of the Jersey Boys, I can’t say I’m sorry to see them go.