Judge Alina I. (“AIM”) Marshall is willing to credit Jack Donald Supinger, T. C. Memo. 2025-93, filed 9/4/25, with semi-repentance when she adds on Section 6651(a) failure to file and chops Jack Donald with $10K for Section 6673 frivolity.

Jack Donald has been here before. See my blogposts “Holding Out the Lamp,” 10/29/21, “Holding Out the Lamp – Part Deux,” 1/14/24, and “Rainy Days and Mondays,” 2/12/24.

Judge AIM Marshall goes over Jack Donald’s frivolite past, his written recantation, and his evasive trial testimony. And the warnings; oh, did Jack Donald get warnings.

IRS has BoP on the 6651(a) add-on, as they claimed Section 6662(a) in their answer, except Jack Donald filed an all-zeros for year at issue, and that flunks Beard. That wasn’t a good-faith effort to self-assess, not did it give IRS the information so to do. so no return was filed. But it’s a walkover, as Jack Donald puts in no evidence to counter.