I scan the Tax Court website every working day for something new. I’m sure my readers join me in the Acts 17:21 routine.

Today I must disappoint. I found three (count ’em, three) T. C. Memo.s, with nothing but protester jive.

The closest approach to novelty was Albert Mark Fonda, T. C. Memo. 2025-60, filed 6/5/25. Albert Mark claims he isn’t him, T. C. Memo. 2025-60, at p. 3, despite admitting having been born in NYC and living in TX. The rest is the usual Subtitle A – Subtitle C mishmash. Judge Albert G. (“Scholar Al”) Lauber needs little scholarship to invoke Crain and Wnuck. And because “(P)etitioner’s litigating strategy has required the Court to issue at least 25 pretrial Orders and conduct a lengthy discovery hearing,” T. C. Memo. 2025-60, at p. 4, Scholar Al gives Albert Mark a $7500 Section 6673 frivolity chop at no extra charge.

 Judge Rose E. (“Cracklin'”) Jenkins draws a simple wages-aren’t-taxable in Christopher L. Huber and Ashley M. Huber, T. C. Memo. 2025-59, filed 6/5/25. It’s Ashley’s wages. She conflates Section 6702 frivolous returns (not subject to deficiency procedures) with Section 6213 deficiencies; see T. C. Memo. 2025-59, at p. 7. In any case, Ashley loses, and gets the Section 6673 yellow card at no extra charge.

But Kent Trembly, T. C. Memo. 2025-58, filed 6/5/25, gives Judge “Cracklin'” Jenkins a look at Kent’s third appearance on this my blog. The previous appearances related to IRS tactics of which I disapproved, but now Appeals has cleaned up its act when AO 1 thought a restitution-based assessment was the subject of a deficiency, when it was really Section 6663 fraud chops after Kent pled to Section 7206 filing false returns in USDCDNE.

“…(A)cknowledging that this Court may find his arguments frivolous, he advances arguments about the IRS not being an agency of the U.S. government. He also states: ‘After we received [the First AO’s Initial NOD] . . . [the First AO] NEVER answered his phone and I left him one or two voice mail messages. I believe he steadfastly refused to answer my calls . . . .'” T. C. Memo. 2025-58, at p. 6.

Kent follows this with repeated stalling at the supplemental hearing, claiming he needs time to find a tax lawyer.

As to the unresponsiveness of AO 1 “(T)he First AO did not abuse his discretion by not speaking to petitioner after the case was closed and the Initial NOD was issued, particularly given that petitioner did not provide the financial information that the First AO requested. The Court has found that when Appeals provides a taxpayer a reasonable deadline to provide information, the taxpayer is expected to meet that deadline, and it is not an abuse of discretion for Appeals to reject collection alternatives and sustain the proposed collection action if the taxpayer fails to meet that deadline.” T. C. Memo. 2025-58, at p. 15.

For the frivolous arguments checklist, see p. 16.