Tax Court judges don’t do tax prep; that’s why we have Rule 155 beancounts. The opinion sets out the appurtenant principles. Each party does the arithmetic in conformance therewith. If they don’t agree, they can only fight about numbers.

If one party is unhappy with the principles, they can seek reconsideration (Rule 161) or revision (Rule 162) but they have only 30 (count ’em, 30) days to do it. As this is Tax Court, of course the 30 day period starts to run from a different point under each Rule.

Of course, there is a right of appeal in regular cases, but that arises only after entry of the decision which incorporates one of the Rule 155 submissions.

Judge Alina I. (“AIM”) Marshall continues the CPE class she started a year ago in Kenneth Steven Tuma, Sr. & Deborah Ann Tuma, Docket No. 15553-18, filed 7/9/25. Part One of the lesson can be found in my blogpost “Cannot Be Proved Too Often,” 7/11/24.

Ken wants a stay while he appeals. IRS wants more time to do their numbers. As this is extension number four, Judge AIM cautions the parties they’re not getting any more after this one, despite Ken’s ill health and IRS’ innumeracy. But there’s no stay.

“If a party disagrees with the opinion, then it follows that the party will also disagree with the computation. He will disagree even with his own computation, since his computation must be based on an opinion that he thinks is incorrect. But nonetheless his task is to perform the computation according to that opinion. His task is not to perform a computation according to the opinion he thinks the Court should have issued – but rather, to perform a computation according to the opinion the Court did issue. If a party disagrees with the Court’s opinion (and with the decision entered in accordance with it), then that party’s remedy would be an appeal from the Court’s decision, see Rule 190 and I.R.C. §7482, after that decision has been entered.” Order, at p. 1.

So do the numbers.

Edited to add, 7/10/25: And note that the bond you’ll need to post per Section 7485(a)(1) will be based upon the computation with which you disagree.