Long-time readers of this my blog may remember Kumar Rajagopalan’s and Susamma Rajagopalan’s five (count ’em, five) appearances in this my blog, ending in their total Dixieland Boondockery win. What, no? How fleeting is fame!  Then see my blogpost “No Head-banging, No Penalty,” 11/19/20.

OK, Kum and Sus have gone home winners. So why does Judge Mark V. (“Vittorio Emanuele”) Holmes recall their win today?

Because Warren C. Sapp & Jamiko Sapp, Docket No. 21575-11, filed 8/14/25 want Section 7430 legals. Warren & Jamiko were in on the deal with Kum & Sus.

Football fans know Warren as the 13-year NFL Hall of Fame defensive tackle with the Tampa Bay Buccaneers and Oakland Raiders. This gives Judge Holmes a chance to inject football jargon into his order.

Problem is, despite getting smashed on the trial (see my blogpost aforementioned), IRS’ positions at time of answer weren’t unreasonable. This even though subsequent appellate learning sank a lot of it. While the taxpayers’ appraisal had the right number, it had sufficient imperfections in getting there to leave room for doubt. The NC market boom leading up to the appraisal was an eyeopener sufficient to raise at least one eyebrow. And the claimed qualified offer, though the right number, failed to satisfy the statutory criteria.

And all this despite IRS’ utterly lackluster pleadings in defense of Warren’s and Jamiko’s motion. See Order, at p. 4, footnote 2.

Judge Holmes, obviously impressed by Warren’s athletic prowess and legal team’s agility (including a faithful reader of this my blog; Good Try, Ms. L), gives a lengthy review of the facts that IRS should have pled and documents that IRS should have introduced in support.

Judge Holmes vies with Judge David Gustafson for an obliging nature.