The old wheeze says “When the law is against you, pound the facts; when the facts are against you, pound the law. When both facts and law are against you, pound the table.”

Taishoff says, when the numbers are against you, smile your sweetest, go into the hallway and sob.

Christopher B. Epps, T. C. Memo. 2025-85, filed 8/7/25, neither makes an offer for an IA or PPIA, nor for CNC. So Ch J Patrick J. (“Scholar Pat”) grants IRS summary J sustaining the NITL gave him.

See T. C. Memo. 2025-85, at p.5, final paragraph, for the real story.

Chris’ trusty attorney deserved better.