Corri A. Feige, T. C.  Memo. 2025-88, filed 8/18/25 claims the stock in her employer that she got when she was terminated wasn’t hers (hence nontaxable) because treasure trove per AK law. Termination of employment did terminate Corri’s rights in her employer’s stock plan, but Corri’s efforts to return the stock (a couple phonecalls and e-mails; hi, Judge Holmes) fell well short of renouncing same.

Since Corri had neither noncompete nor obligation to refund past compensation, Section 83 o’ercrows Section 61. Besides, Corri knew she and her ex-employer were the only ones with claims to the shares, unlike the cash-in-the-piano case where there might be multiple claimants.

Corri had unfettered right to sell or pledge; no possibility of forfeiture.

Corri claims she didn’t file for year at issue, despite having filed for years before and after, because of personal problems (not bad enough says Judge Alina I. (“AIM”) Marshall). Her husband knew from nothing and always did the taxes using TurboTax. And Corri lived in the remote wilderness (Chickaloon, AK) where there were no tax gurus.

“Petitioner argues that her failure to timely file the return was ‘reasonable under the circumstances because the tax issues presented were complex and outside of petitioner’s understanding.’ She further argues that she intended to file the return but could not because of the complexity of the issue and the lack of readily available tax professionals in the remote part of Alaska where she lived. Petitioner notes that [year at issue] was the only tax year for which she and her husband failed to file a tax return. Additionally, petitioner argues that at the time the return was due she experienced personal hardships that compounded the problem, including her unemployment and the illness and death of her father. Finally, she argues that she exercised ordinary business care to resolve the issue by requesting to have tax withheld from any distribution of shares under the [employer stock plan] and contacting [employer] to recover the shares.” T. C. Memo 2025-88, at p. 18.

Judge AIM Marshall ain’t buying.

“Petitioner was not limited to finding a tax professional in or around Chickaloon. During her employment with [employer], petitioner routinely travelled 80 miles from her home in Chickaloon to [employer]’s office in Anchorage. We note that petitioner’s attorney in this case is also based in Anchorage. There is no reason she could not have sought out a tax professional based in Anchorage when the issue originally arose…. Additionally, she could have consulted with a tax professional based outside Alaska through phone calls or email. The fact that petitioner resides in a remote location does not excuse her failure to seek out a tax professional to advise her on the issue, complex as it may have been.” T. C. Memo. 2025-88, at p. 19.

Corri gets nailed for failure to file, but not failure to pay tax due or estimateds for year at issue. IRS’ records show they prepared and mailed a SFR, but they put in neither SFR nor copy thereof, nor any other document showing sufficient information from which to compute the taxpayer’s tax liability, nor did any form and any attachments purport to be a return. And since prior year’s return never went in either, no showing that a 1040-ES was necessary either.

A Taishoff “Good Job, Second Class” to Corri’s trusty attorney.