It’s a tried-and-true failure, but Steven J. Schwartz, T. C. Memo. 2025-64, filed 6/16/25, tries it on again. Steve (that’s Doc Steve) wants his unpaid 1040-ES for a couple years (hi, Judge Holmes) folded into his IA.

As the Appeals officer noted, Dr. Schwartz was not in compliance with his estimated tax obligations for 2022 or 2023, part of a pattern of significant underwithholding of tax stretching back to at least 2017. Dr. Schwartz does not assert that he was in compliance with his estimated tax obligations. He instead offers a strained and tendentious reading of the Internal Revenue Manual that would require the Appeals officer to grant Dr. Schwartz an installment agreement that included the delinquent estimated tax payments.” T. C. Memo. 2025-64, at p. 7.

Ch J Patrick J. (“Scholar Pat”) Urda isn’t having any.

“We have repeatedly rejected the argument Dr. Schwartz urges here.” T. C. Memo. 2025-64, at p. 7.

There follows somber reasoning and copious citation of precedent. Yes, the AO could have let Doc Schwartz fold his unpaids in, but committed no abuse of discretion in not doing so.