Fallout continues from the demolished two-stage structure that was TEFRA. Whether IRS properly mailed the FPAA to a notice partner, when said partner was an indirect partner, is yet another chapter in the Scott Blum saga.

Scott is trying to get Judge Goeke to reconsider his decision, which tagged Scott with a massive whack from a collapsed tax shelter. The basic story can be found in my blogpost “Thirteen Years,” 2/18/25.

I’ll repeat what I said then: “I’ve paid good money for whiskey younger than this case.”

Once again, Rule 161 reconsideration is a broken reed.

“The U.S. Court of Appeals for the Tenth Circuit, to which this case is appealable unless stipulated to the contrary, has identified the following grounds for granting of a motion of reconsideration: (1) an intervening change in the controlling law, (2) new evidence previously unavailable, and (3) the need to correct clear error or prevent manifest injustice.” Order, at p. 1.

Here, Scott has none of the above. The case is Scott A. Blum and Audrey R. Blum, Docket No. 5313-16, filed 4/30/25.