I must give hearty, though belated, thanks to Judge Mark V. (“Vittorio Emanuele”) Holmes for an analogy that has worn well: “(T)he silt we stir today will cloud the cases we plunge into tomorrow.” 137 T. C. 17, at p. 61.” See my blogpost “The Great Dissenter,” 12/28/11.

I wish my high-priced refrigerator (kaput for the second time in less than two (count ’em, two) years) had worn half as well.

Judge Ronald L. (“Ingenuity”) Buch took a 500 hp Mercury outboard to the silt in Veribest Vesta, for which see my blogpost “Judge Buch Says It All,” 7/15/25. And the muddied waters are swirling about Judge Albert G. (“Scholar Al”) Lauber, as he tries to quieten the allegedly spooked trusty attorneys for Ivey Branch Holdings, LLC, Ivey Branch Investors, LLC, Tax Matters Partner, Docket No. 19189-19, filed 8/14/25.

Among said trusty (but allegedly spooked) attorneys is the redoutable Vivian D. (“Golden”) Hoard, Esq., who with her crew gets a Taishoff “Good Try, Third Class.”

“… petitioner filed a Motion to Stay Proceedings, requesting that the Court stay proceedings in this case pending resolution of appeals from this Court’s decisions in Ranch Springs, LLC v. Commissioner, 164 T.C. No. 6 (2025), and Beaverdam Creek Holdings, LLC v. Commissioner, T.C. Memo. 2025-53. Petitioner’s counsel urge that they face a dilemma: Zealous advocacy dictates that they continue to embrace the discounted cash flow valuation method rejected in Ranch Springs and Beaverdam Creek, but doing so could risk sanctions in light of views expressed in a recent bench opinion delivered by another Judge of this Court. See Veribest Vesta, LLC v. Commissioner, Docket No. 9158-23, Entry No. 194, Transcript of July 11, 2025 (Bench Op.).” Order, at p. 1.

Judge Scholar Al, perhaps with a muted sigh and uplifted eyes, rejects.

“Petitioner’s request for a stay ignores the bifurcated nature of this trial. The first phase of trial is limited to taking the testimony of fact witnesses and experts whose testimony does not implicate valuation or geological evidence…. We will not hear expert testimony implicating valuation until the second phase of trial…. Petitioner will thus have no occasion to engage in ‘zealous advocacy’ regarding the appropriate valuation method during the initial phase of trial. In any event, the undersigned will not entertain any Motion to Impose Sanctions prior to a definitive appellate court ruling on the subject.” Order, at p. 1.

It’s not only Judge Ingenuity Buch who brings ingenuity to Tax Court practice.